Modern Slavery Policy

Modern slavery is a crime and a violation of fundamental human rights.  It takes various forms, such as slavery, servitude, human trafficking and forced and compulsory labour; all culminating in the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

Genius has a zero-tolerance approach to modern slavery.  We are committed to acting ethically and with integrity and transparency in all our business dealings and relationships.  We aim to implement and enforce effective systems and controls to ensure modern slavery is not taking place within our own business or anywhere in any of our supply chains. 

Genius expects the same high standards from all our contractors, suppliers, clients and other business partners and we expect that they will hold their own suppliers to the same high standards.

This policy applies to anyone working for us or on our behalf in any capacity, including all directors, officers, employees, contractors, agency workers, volunteers, interns, agents, external consultants, third-party representatives, and business partners.

This policy does not form part of any employee’s contract of employment, and we may update it at any time.

Right to Work

We conduct eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.


You must ensure that you read, understand, and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or on our behalf.  All such individuals are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify the Managing Director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains of any supplier at the earliest possible opportunity.  If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify the Managing Director in accordance with our Whistleblowing Policy as soon as possible.

If Genius becomes aware of any supplier, or business partner of any kind, allowing coercive, abusive and exploitative work practices in their own business or supply chains, our policy is to immediately alert them and request changes be made.  If they are unwilling to act and/or do not immediately implement change, we will terminate the relationship.  If Genius has substantive grounds to suspect modern slavery, we will alert the appropriate authorities whenever possible.

If you are unsure about whether a particular act, the treatment of workers more generally, their working conditions within any of our supply chains constitutes any of the various forms of modern slavery, you should raise it with the Managing Director.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.  We are committed to ensuring no one suffers any detrimental treatment for reporting in good faith their suspicion that modern slavery is, or may be, taking place in any part of our business or in any of our supply chains.  Detrimental treatment would include dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern.

If you believe that you have suffered any such treatment, you should immediately inform the Managing Director. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.


Genius has overall responsibility for ensuring this policy complies with our legal and ethical obligations and that all directors, officers and employees comply with it.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and our supply chains, we provide access to training for relevant members of staff.

An introduction to this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us and any updates are provided using established methods of communication.

We aim to communicate our zero-tolerance approach to modern slavery to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforce this as appropriate thereafter.

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Managing Director.


Any employee who breaches 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.

Training Resources

All members of the Genius team and all its stakeholders are encouraged to explore all available resources and put forward suggestions to ensure continual improvement and

This policy is made pursuant to the Modern Slavery Act 2015 and was approved and signed by:

Emma Humphrey

Managing Director

October 2023