Modern Slavery Policy: Digital Works Group

Last updated in June 2024

1. Introduction

This statement sets out the steps taken by Digital Works Consulting Limited (trading as Digital Works Group) to understand all potential modern slavery risks related to our business, and to put in place steps which are aimed at ensuring that there is no slavery or human trafficking in our own business and our supply chains. This statement relates to actions and activities during the period 1 April 2024 to 31 July 2025.

2. Organisational structure, operations & supply chain

Digital Works Group launched in 2011 with the simple mission to “do things a little differently” and always put our clients’ needs first. Over that time, we have grown our organisation to over 40 senior experts. Creating a ‘boutique’ business transformation and innovation consultancy, passionate about unlocking new opportunities or solving business problems via digital, data and AI.

Consulting which delivers benefits

Unlike many traditional consultancies we are outcome focused. We don’t just help our clients to ‘work out the right plan’, but also ‘help’ them to successfully execute the right solution which we couple with proven working practices aimed at empowering our client’s teams with knowledge and capabilities ongoing, releasing real and sustainable business benefits.

Our Team + Rich ecosystem of partners

Our team are not career consultants. All of us are highly experienced people from industry, who, together, possess exceptional digital knowledge across many disciplines. They are also all owners of our business, creating a balanced, open, fair and collegiate approach to our business.

We are supported by a rich ecosystem of best-in-class partners. Meaning we can provide clients with proven support in the pursuit of all their (digital, data and AI) business needs.

Values based approach

We live out our values which we all took time to input and develop. They are important to us and we actively seek partner organisations with similar values and outlook. In every dealing with every fellow human being, we seek to be;

  • Impactful – focused on delivering real business benefit and value
  • Empowering – educating and transferring skills and knowledge
  • Human – strong relationships, working collaboratively and empathetically
  • Uncomplicated – clarity, simplicity, but with a customer-centric ethos
  • Trustworthy – open, honest, fair and committed.

Meaning a forced, controlling & manipulative behaviour has no place in DWG or its supply chain.

Countries of operation and supply

Digital Works Group is mainly UK based although it will take assignments from other parts of the world on a reactive basis. Consultants are encouraged to live close to cities and/or good transport links to be able to access client sites, but that aside, but they really are free to work and live out their values anywhere!

3. Managing risk

Ensuring that modern slavery or human trafficking has no place in our business or supply chain is not always straightforward and can easily become a box ticking exercise within smaller organisations. The profile of risk differs widely across industries and areas of operation and DWGs board recognise that, within UK consulting and its associated supply chain, the current risk factors are relatively low so introducing onerous and time-consuming checks and balances is not going to have much impact. DWG recognise this risk and perceive there to be greater importance to embed key principles and values into our culture so that they impact behaviour without even thinking:

Why is modern slavery incompatible with DWG’s values?

  • As DWG are committed to Empowering and equipping employees, clients and suppliers, but we understand that to ensure slavery and human trafficking is not taking place anywhere in our supply chain, further controls may be necessary.
  • As being Human is something we universally share, we recognise value in each individual and choose to honour & collaborate with anyone, especially those whose rights & freedoms are being infringed & even those who may not – as yet – earned our respect.
  • We seek to be Impactful and regarding ending the practice of forced labour, we support the aims of the Modern Slavery Act 2015 and are committed to complying with applicable anti-slavery and human trafficking laws. We evidence this through the fairness and commitments in our contracts, and our management practices.
  • Our Anti-Slavery & Human Trafficking statement reflects our commitment to being Uncomplicated to do business with, however we understand that the severity of the risk may mean implementing and enforcing further systems and controls.
  • We are Trustworthy, acting ethically & with integrity, in all our business relationships & so we ensure that we follow processes to assess the risk of modern slavery from our suppliers:

How do we control our vendor risk?

  • We assess the risk profile of any new supplier or partner via the application process.
  • If they fall into a medium or high-risk category, or wish to become a strategic partner, we conduct further assessments before entering a commercial relationship – these may either be questionnaires or structured interviews.
  • We review the potential for risk at regular intervals, including the possibility of re-assessing a supplier or conducting spot checks.
  • We require our suppliers and partners to address modern slavery concerns in their policies.
  • Only senior partners who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.
  • Our staff are encouraged to bring any concerns they have to the attention of management.

How do we engage our employees?

  • We have a zero tolerance to slavery and human trafficking, and we expect our employees to encourage our supply chain and contractors to comply with our values. We include appropriate clauses in our supply contracts.
  • We have in place systems to encourage the reporting of concerns and the protection of whistle blowers as reflected in our Whistleblower Policy.
  • We continue to review our policies, training, processes, operations and supplier relationships to comply with the Modern Slavery Act 2015 and will implement any appropriate or necessary actions to ensure ongoing compliance with the Modern Slavery Act 2015.

What do we measure?

Due to the relatively low risk overall, with much of the value being delivered is upstream preventative controls, behavioural elements, contracts and relevant processes, zero tolerance attitude – means we have not formally identified any KPIS. Instead, the DWG board will be informed on a regular basis,

  • the effectiveness of enforcement against suppliers who breach policies
  • the amount of time spent on assessments, re-assessments, spot checks, & related due diligence
  • the level of modern slavery training amongst our staff

4. Relevant Policies

Digital Works Group operates the following policies that support our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

Anti-Slavery and Human Trafficking Policy

We make space for any employee who wishes to raise a concern; they can do so on an anonymous basis if necessary.

Employee Code of Ethics

Digital Works Group’s Code of Ethics is the code by which directors, officers, employees and contractors of Digital Works Group are expected to always conduct themselves. All Digital Works Group business is conducted with the highest standards of integrity and in compliance with all applicable laws and regulations. This code applies to Digital Works Group and all its subsidiaries worldwide.

Recruitment/Agency T&Cs

Digital Works Group uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. All new agencies are required to sign an agreement to conform to the standards of Digital Works Group.

Due diligence

Digital Works Group continues to conduct appropriate due diligence when considering taking on new suppliers and the review of its existing suppliers. Where possible we build long standing relationships with local suppliers and make clear our expectations of business behaviour as reflected in our Code of Ethics.

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 all relevant employees regarding:

  • how to identify the signs of slavery and human trafficking;
  • what initial steps should be taken if slavery or human trafficking is suspected;

5. Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s Slavery and Human Trafficking Statement.