Statement of Anti Slavery & Human Trafficking


This policy sets out to understand all potential modern slavery and human trafficking risks related to business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in own business and supplier/partner organisations. Mirabelle Communications maintains relationships with many different organisations, as well as directly employing a number of people. In light of the general law on employment and human rights and more specifically, the Modern Slavery Act 2015, our company is absolutely committed to preventing slavery and human trafficking in its corporate activities and ensuring that its services are free from slavery and human trafficking.

Organisational Structure

This policy covers all the activities of Mirabelle. It governs all our business dealings and the conduct of all people or organisations with whom we contract directly or who we appoint to act on our behalf. Same we expect all who have, or seek to have, a business relationship with Mirabelle and/or any member of our organisation, to familiarise themselves with our anti-slavery policy and to always act in a way which is consistent with our anti-slavery policy. The company currently operates in the United Kingdom.


The Management will liaise with other relevant departments such as the HR & Admin, Client Account Management Teams and Finance Team to ensure that risk analysis and investigations/due diligence in relation to modern slavery and human trafficking are carried out as required. HR & Admin will ensure that employees are given adequate and regular training on the issue of modern slavery so that everyone understands and complies with this policy.

Relevant Policies and Practices

Mirabelle operates the following policies and practices that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations. The company’s policy on DRD (Direct Report to Director) encourages all its workers, customers/clients, and other business partners to report any concerns related to the direct activities of the organisation or its services. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. This company’s policy procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. Employees who have concerns can directly report to the director of the company by mail or meet directly. The nature of the complaint will determine the next course of action. We endeavour to carry out our own recruitment activities and/or to only use reputable employment agencies to source labour and we carry out appropriate background checks. Personnel responsible for the recruitment activities in any of the subsidiaries are advised to adhere to this policy by ensuring that strict verification of potential employee’s right to work is carried out before any offer of employment is made. Mirabelle expects its suppliers/partners to adhere to recruitment practices that ensure that all terms of employment are voluntary. Where necessary and if required, we may request demonstration of compliance with this policy. This policy on modern slavery will be communicated to all suppliers/partners, contractors, and business partners at appropriate points during our business relationship with them and reinforced as appropriate thereafter.

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: Completion of House Audits by Directors and Managers; Use of labour monitoring and payroll systems; and Level of communication and personal contact with next link within the organisation and their understanding of, and compliance with, our expectations.

Breaches of this Policy

Any employees who breach this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.