Modern Slavery Policy


At Createch, we are committed to conducting our business operations ethically and responsibly. We recognize the seriousness of modern slavery and human trafficking as grave violations of human rights and are dedicated to preventing and addressing these issues within our operations and supply chains.

This Policy establishes our baseline principles and the steps we take to help ensure modern slavery and human trafficking do not occur in our supply chain or business. It provides a framework for compliance and effective risk management under our Code of Conduct, Partner Code of Conduct, and United Nations Declaration of Human Rights. Where applicable law, rule, regulation, or contractual obligation requires a higher standard, we will follow the requirements of that law, rule, regulation, or contract.


This Policy applies to all Createch team members who work for wholly and majority-owned subsidiaries of Createch Agency LLC, including employees, contractors, or contingent workers of each of these entities. Createch subsidiaries outside of the U.S. are expected to adopt and implement this Policy or a local version of this Policy in accordance with applicable laws to bring this Policy into effect locally. The Policy Commitment, Principles, and Operating Standards also apply to our vendors and suppliers who process or otherwise handle data for or on behalf of Createch Agency, and any other third parties, to whom Createch Agency may obligate by contract or other agreement to comply.

Legal Framework

Createch acknowledges its obligations under the Modern Slavery Act 2015 and other relevant national and international laws and regulations pertaining to modern slavery and human trafficking. We are committed to ensuring that our business operates in a socially responsible way that prevents slavery and human trafficking. We are also committed to playing our part in helping the world to improve practices designed to combat slavery and human trafficking. We are not aware of any allegations of human trafficking/slavery activities against any of our current suppliers. If such allegations arise, we will immediately conduct an inquiry and report it to the authorities where required.


The following five Principles guide the way we work to meet our Policy Commitment:
  • Modern Slavery and Human Trafficking: We do not tolerate the use of modern slavery, child labor, forced labor, or human trafficking in any form in our organization or supply chain.
  • Global Supply Chain: We expect third parties throughout our global supply chain to support human rights and encourage third parties to adopt standards consistent with the principles established under the United Nations Declaration of Human Rights.
  • Third-Party: Screening and Monitoring: We conduct screening and due diligence on third parties, both at the time of onboarding and contract renewal, for human trafficking and modern slavery alerts and red flags.
  • Training: We provide training to our employees and third parties on recognizing and reporting modern slavery, human trafficking, and forced labor. We train team members to do their part to respect the human rights of people in communities that are impacted by our activities and report any human rights abuse that they see or suspect either in our operations or in those of our business partners.
  • Recruitment and Hiring: We have recruitment and hiring processes to safeguard against modern slavery, human trafficking, or forced labor.

Policies and Procedures

We have implemented the following policies and procedures to address modern slavery:

  • We provide training and awareness programs to our employees to recognize and report signs of modern slavery and human trafficking.
  • Createch upholds fair and ethical recruitment practices and does not tolerate any form of forced or involuntary labor.
  • We have established confidential reporting channels for employees and stakeholders to report concerns or suspicions of modern slavery without fear of retaliation.

Monitoring and Review

We regularly monitor and review our efforts to combat modern slavery and ensure effectiveness and compliance with this policy. We commit to conducting periodic risk assessments and updating our policies and procedures accordingly.

Communication and Transparency

Createch communicates its commitment to combatting modern slavery through:

  • Publicly available disclosure of our modern slavery policy.
  • Transparency in reporting our efforts to address modern slavery issues.
  • Leadership Accountability
  • Leadership at Createch is accountable for:
  • Ensuring compliance with this policy.
  • Promoting a culture of ethical conduct and respect for human rights.


Createch prohibits retaliation against individuals who report concerns or cooperate with investigations related to modern slavery.

Breach of the Policy

Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct. If we discover a violation of our Anti-Slavery Policy, we will respond in a manner proportionate to the nature and extent of the violation. Serious violations will require immediate and decisive action and may result in the termination of the business relationship. For less serious violations, we will allow the supplier reasonable time to develop and implement a remediation plan. We will treat termination as a last resort as it is unlikely to resolve the underlying issue and it may be detrimental to those people who rely on the work to survive.

Looking Ahead:

Createch is dedicated to upholding the principles outlined in this modern slavery policy. We will continue to assess our business and supply chains to identify potential modern slavery risks and target those areas with policies, procedures, and trainings to ensure we maintain appropriate safeguards to mitigate those risks.