MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

 Introduction

 This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 01 April 2024. Positive 4 mind ('the Company', 'we', 'us' or 'our') is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values. Organisational Structure Positive 4 mind is the subsidiary of the Leslie Media Group, the parent company being Leslie Media Group Ltd, and has business operations in the United Kingdom. 

We operate in the Media sector.

The nature of our supply chains is as follows: 

We provide media solutions to a number of fast growing sectors and employ people on 2 different continents providing marketing services 

For more information about the Company, please visit our website: positive4mind.com/about.html. 

Policies We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. 

These include the following:

Recruitment and selection policy - As an equal opportunities employer, we're committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. 

We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves. Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and Venezuela and to safeguard employees from any abuse or coercion. 

We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour. 

Whistleblowing policy -

We operate this policy so that employees are able to raise concerns about how staff are being treated or practices within our business or our supply chains without fear of reprisal. 

Staff code of conduct -

We are committed to the fair treatment of all staff. Our staff code of conduct reflects our core values and expected behaviours. 

The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery. 

Safeguarding policy -

This policy highlights the potential risks of modern slavery and human trafficking, including how to identify signs of exploitation and how to report concerns. We make sure our suppliers are aware of our policies and adhere to the same standards.

 Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures: 

Internal supplier audits. 

External supplier audits.

Our due diligence procedures aim to: Identify and action potential risks in our business and supply chains. Monitor potential risks in our business and supply chains Reduce the risk of slavery and human trafficking occurring in our business and supply chains. 

Provide protection for whistleblowers. Risk and Compliance The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through: 

Creating an annual risk profile for key suppliers. Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping. We do not consider that we operate in a high-risk environment because Consider and set out the risks associated with the business, including: country risks (ie there being greater exposure to modern slavery in countries where human rights protections are more limited; sector or industry risks (ie what parts of the business may be vulnerable to modern slavery); and business or transaction risk (ie particular relationships or transactions may be more susceptible to modern slavery).. 

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately. Effectiveness The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. 

These KPIs are as follows:

We will contact suppliers to enquire about their modern slavery practices every 4 months. 

We will train our staff about modern slavery issues and increase awareness within the Company. 

We will carry out a regular audit of suppliers - 50% of suppliers each year. Training Staff The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. 

The Company's training covers:

How to identify the signs of slavery and human trafficking. 

What initial steps should be taken if slavery or human trafficking is suspected. 

How to escalate potential slavery or human trafficking issues to the relevant parties within the Company. 

What external help is available.

What steps the Company should take if suppliers in its supply chain do not implement anti-slavery policies in high risk scenarios, including their removal from the Company's supply chain.