Modern Slavery Policy

Now Ayrshire Radio

Modern Slavery Policy

Effective Date: 30th March 2026

1. Policy Statement

Modern slavery is a serious and indefensible abuse of fundamental human rights. Now Ayrshire Radio recognises its moral and social responsibility to take a zero-tolerance approach to all forms of modern slavery, including forced labour, servitude, and human trafficking.

We are committed to ensuring that slavery and human trafficking have no place in our business operations or supply chains.

We actively work to prevent these practices by reviewing our business activities and engaging responsibly with suppliers and partners. Our approach is aligned with our values and our legal obligations under the UK Modern Slavery Act 2015.

2. Scope

This policy applies to all employees of Now Ayrshire Radio, as well as to our suppliers, contractors, and business partners. It covers all operations, services, and procurement activities under our control or influence.

3. Objectives

The aim of this policy is to identify, prevent, and mitigate the risk of modern slavery across our organisation. We are committed to:
  • Assessing risks within our supply chain
  • Embedding ethical conduct throughout our business relationships
  • Maintaining full compliance with legal and regulatory obligations

4. Current Activity and Due Diligence

We conduct due diligence when engaging new suppliers and periodically review our existing partners. This includes understanding our supply chains to assess whether certain services, products, or geographic areas pose a higher risk of slavery or human trafficking.

We assess potential and existing suppliers through appropriate checks, which may include requesting information relating to their ethical and labour practices.

If any supplier fails to meet our expectations or does not take corrective action within a reasonable timeframe, we reserve the right to terminate the business relationship. This ensures that we only work with partners who share our commitment to ethical labour practices.

5. Supporting Policies

Our wider ethical commitments are supported by internal policies that reinforce this approach.
  • Whistleblowing Policy – Encourages employees to report concerns about unlawful behaviour, malpractice, or risks, including suspicions related to slavery or trafficking.
  • Sustainability Policy – Requires suppliers to provide safe working conditions, treat workers with dignity and respect, and comply with labour laws.
  • Ethical Policy – Outlines the standards of conduct and values expected across all areas of operation.

6. Training and Awareness

Where appropriate, training is provided to employees in roles where modern slavery risks may arise. This includes guidance on:
  • Identifying warning signs
  • Assessing risk
  • Reporting concerns through the correct channels Awareness is also promoted among leadership and relevant staff to ensure a consistent understanding across the organisation.

7. Responsibilities

The Director of Now Ayrshire Radio is responsible for approving and reviewing this policy on an annual basis.

Managers are expected to implement the policy within their areas of responsibility and ensure their teams understand and comply with the organisation’s stance on modern slavery.

All employees have a duty to report any suspected breaches or unethical behaviour. Reports made in good faith will be fully supported.

8. Legislative Reference

This statement is made in accordance with Section 54(1) of the UK Modern Slavery Act 2015 and constitutes Now Ayrshire Radio’s slavery and human trafficking statement for the current financial year.

9. Review and Approval

This policy will be reviewed annually, or sooner if there are significant changes in legislation, organisational structure, or operational risk.

Any updates will be approved by the Director and communicated across the organisation.