Human Rights Policy

Human Rights and Modern Slavery Policy

Applies To: Fonemedia Ltd and IFF Digital Ltd (all staff, contractors, and suppliers)

Fonemedia and IFF Digital are committed to respecting and upholding internationally recognised human rights in all aspects of our business operations. This policy sets out our commitment to conducting business ethically, responsibly, and in a manner consistent with the following international standards and frameworks:

• • United Nations Guiding Principles on Business and Human Rights (UNGPs)
  • UN Universal Declaration of Human Rights
  • ILO Core Labour Standards (covering forced labour, child labour, freedom of association, and non-discrimination)
  • UK Modern Slavery Act 2015
  • OECD Guidelines for Multinational Enterprises

We recognise that human rights risks can arise both within our own operations and through our business relationships, and we are committed to taking proportionate steps to identify, prevent, and address potential adverse impacts.

Governance and Oversight
Board-Level Responsibility
Human rights governance sits within the general compliance oversight responsibilities of the Senior Leadership Team. The CEO, James Dalton, holds accountability for ensuring that human rights commitments are embedded within business strategy and operations, and that any identified risks or concerns are escalated appropriately.

Operational Responsibility
The Group Compliance Director, Samantha Dalton, is responsible for the day-to-day implementation, monitoring, and review of this policy. Relevant managers at all levels are expected to understand and uphold the principles set out in this policy within their areas of responsibility.

Workplace Rights
We are committed to providing a workplace that:

• • Respects the dignity, privacy, and equality of every individual
  • Is free from discrimination, harassment, and victimisation on any grounds including colour, sex, religion, political opinion, national extraction, social origin, age, disability, sexual orientation, or any other characteristic
  • Provides fair and lawful remuneration, including compliance with the National Living Wage as a minimum
  • Upholds the right to reasonable working hours, minimum breaks, and rest periods in accordance with the Working Time Regulations 1998
  • Supports freedom of association and employees’ right to collective bargaining
  • Provides equal pay for equal work and equal opportunities across all levels of employment
  • Does not involve the misuse of security forces or any form of unlawful enforcement

Child Labour and Forced Labour
We have zero tolerance for child labour, slavery, forced labour, human trafficking, or any form of exploitation in our business or supply chain. We will not knowingly engage with any supplier, contractor, or partner found to be involved in such practices. Our approach includes:

• • Prodicing staff with guidance on identifying and reporting concerns
  • Reviewing supplier relationships as part of our ongoing due diligence activity, building on the supply chain review exercise conducted in support of our ISO14001 certification.
  • Maintaining a Modern Slavery Statement (FM076) as required under the Modern Slavery Act 2015, which is reviewing and approved by the SLT annually.

Human Rights Risk Analysis
Commitment to Risk Analysis
We are committed to systematically analysing potentially negative impacts of our operations and business relationships on human rights. Our risk analysis approach considers the following stages of our value chain: our own direct operations, Tier-1 suppliers, and key client relationships.
Potentially Affected Groups
In conducting risk analysis, we consider the following potentially affected groups: employees, contractors and agency workers, supply chain workers, and communities affected by our operations or those of our suppliers.
Human Rights Issues Considered
Our risk analysis considers issues including but not limited to; forced and compulsory labour, child labour, discrimination, harassment, freedom of association, fair pay and working hours, health and safety, and data privacy.
Prioritisation
Identified risks are prioritised based on their potential severity and likelihood of occurrence, taking into account both our direct operations and those of our key suppliers.
Review Frequency
The risk analysis will be reviewed and updated at least annually, or sooner if there are significant changes to our operations, supply chain, or the regulatory environment.

Information Sources
Risk analysis draws on information from: employee feedback and grievance data, supplier due diligence reviews, publicly available country and sector risk indices, and legal and regulatory updates.

Supply Chain Responsibility
We recognise that human rights risks can exist beyond our direct operations. We expect our suppliers and business partners to:

• • Respect human rights in their own operations
  • Comply with all applicable local and international human rights laws
  • Cooperate with reasonable due diligence requests from Fonemedia or IFF Digital
  • Notify us promptly if they become aware of any human rights concern in their operations

Supply chain due diligence is conducted as part of our ongoing compliance activity. Findings are reviewed at SLT level as part of the annual ISO 9001 and ISO 14001 Management Review, and any corrective actions are tracked through to completion. Failure to meet our standards may result in termination of the business relationship.

Preventive and Remedial Measures
Training
All employees will receive training on human rights awareness as part of their induction and on an ongoing basis. Training covers recognition of human rights risks, including child and forced labour indicators, non-discrimination, and how to raise concerns.
Procurement Integration
Human rights and labour rights factors are integrated into our procurement approach. Supplier selection and ongoing relationships take into account adherence to applicable human rights standards.
Health and Safety
We are committed to providing safe and healthy working conditions for all staff in line with our Health & Safety Policy. Health and safety performance metrics are tracked and reported internally on a regular basis.
Remediation
Where actual negative impacts on human rights are identified, we are committed to providing or cooperating in remediation. This may include corrective action plans, changes to processes or supplier relationships, or other appropriate measures depending on the nature of the impact.

Effectiveness Monitoring
The effectiveness of measures taken to address human rights risks will be reviewed at least annually by the Group Compliance Director. Findings will be used to inform updates to this policy and associated procedures.

Grievance Mechanism
We provide a formal internal complaint mechanism accessible to all employees. Concerns can be raised through:

• • Line Managers
  • Group Compliance Director (directly and in confidence)
  • The company’s Whistleblowing Policy

All complaints are taken seriously, investigated in a timely manner, and handled confidentially. Employees are protected from retaliation for raising concerns in good faith. Issues covered by the grievance mechanism include discrimination, harassment, forced or child labour concerns, health and safety, and any other human rights matter relevant to the workplace.

Documentation and Record Keeping
Records relating to human rights risk analysis, preventive and remedial measures, and complaints received will be retained for a minimum of seven years in line with our document retention procedures.

Reporting
Human rights due diligence implementation is reviewed by the SLT on an annual basis. This includes a summary of risk analysis findings, measures implemented, training completed, and any complaints or incidents recorded during the year

Related Policies

• • Equal Opportunities Policy (FM046)
  • Anti-Harassment and Bullying Policy (FM078)
  • Whistleblowing Policy (FM049)
  • Health & Safety Policy (FM050)
  • GDPR Policy (FM054)
  • Environmental Policy – ISO14001
  • Modern Slavery Statement (FM076)