INTRODUCTION
Code and Theory is committed to making meaningful and long-lasting improvements to workers’ employment and workplace conditions including, but not limited to, the prevention of forced, bonded and trafficked labor. This is upheld through the Company’s policies and governance and is supported by a committed organization and leadership.
The California Transparency in Supply Chains Act of 2010 (SB 657) and the United Kingdom Modern Slavery Act of 2015 require certain businesses to provide disclosures concerning their efforts, if any, to address the issues of slavery and human trafficking in their supply chains. This Slavery and Human Trafficking Statement is responsive to the California Transparency in Supply Chains Act and the United Kingdom Modern Slavery Act. Slavery and human trafficking remain a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. Code and Theory personnel are expected to report concerns and management are expected to act upon them.
ORGANIZATION’S STRUCTURE
Code and Theory is an internationally renowned digital design and marketing agency. We currently have offices in New York and San Francisco with two wholly owned subsidiaries in London, United Kingdom and Philippines. The group has an annual turnover in excess of £36m.
OUR BUSINESS
Our business creates products, content and campaigns across physical and digital worlds providing branding and marketing to a diverse and worldwide clientele.
OUR SUPPLY CHAINS
Code and Theory has a supply chain network that exists to support the production of its digital design and marketing services, as well as networks relating to its day-to-day business operations. The primary supply chain network consists of the sourcing of computer equipment and related computing peripherals as well as networking with business associates who provide services to complement our development of digital design and marketing services.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk -
We run licensed premises as managed offices to ensure optimum control of the work environment;
We limit the geographical scope of our licensed premises to ensure optimum supervision of the use of our properties;
Where possible we build long-standing relationships with suppliers, business associates and clientele and make clear our expectations of business behavior;
With regards to national or international supply chains, we prefer to work with a U.S. or a UK company or branch and we expect these entities to have suitable anti-slavery and human trafficking policies and processes as mandated by their local laws. We expect each entity in the chain to, at least, adopt ‘next-step’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the supply chain. We have in place systems to encourage the reporting of concerns and the protection of whistle-blowers.
SUPPLIER ADHERENCE TO OUR VALUES
We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain comply with our values. Our Directors are responsible for ensuring that supply chain entities are those that are located in regions bound by and required to enact anti-slavery and human trafficking policies.
TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All Directors have been briefed on the subject.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
Completion of Supply Chain audits by Company Legal Managers;
Use of labor monitoring and payroll systems; and
Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations.
This statement is made pursuant to the California Transparency in Supply Chains Act of 2010 (SB 657) and the United Kingdom Modern Slavery Act of 2015 and constitutes our group's slavery and human trafficking statement for the current financial year. Approved by the Board on January 31, 2025 and signed on its behalf by:
Anshu Bhargava
General Counsel
Code and Theory LLC