Anti-Slavery Statement

Business Ethics: Anti-Slavery 

Disguise Technologies is committed to the highest standards of professionalism, ethical behaviour and integrity in everything we do and to contributing to the wellbeing of communities around the world. We have a zero-tolerance approach to all human rights abuses and unethical behaviour in business practices generally. Our policies and practices regarding Equality and Diversity, Anti-Bribery, Whistleblowing, Worker Agreements and Environmental, Social and Governance (ESG) speak to these aims. One of the most important aspects of our approaches towards labour practices both within and outside our organisation pertains to our commitment to opposing modern slavery in all its forms. The business does not tolerate abuses of the Modern Slavery Act within our business itself or within our supply chain. 

Anti-Slavery Statement 

1.1. This statement is on behalf of the parent company Disguise Technologies Ltd including its global entities: disguise Systems Ltd., disguise EMEA Ltd., disguise Inc., disguise China and disguise Hong Kong pursuant to Section 54(1) of the Modern Slavery Act 2015. References to "disguise Technologies", "we", "us", "our" or the "firm" are to these named entities. 

Our Organisation Structure 

2.1. Disguise Technologies is a Software/Hardware as a service and professional creative services enterprise company operating through six separately constituted and regulated legal entities globally on a mission to provide the next generation of collaborative tools to help artists and technologists realise their vision. This is achieved in accordance with the relevant laws of the jurisdictions in which they respectively operate. Further information about disguise Technologies can be found on our website https://www.disguise.one/ .

2.2 Disguise Technologies predominantly employs professionally qualified and highly skilled people. Our supply chain consists of goods and services procured to enable our people to deliver their expertise, principally the creation, implementation and use of media technology services and platforms. We consider the risk of Modern Slavery occurring within our business and supply chain to be low. 

Our Supply Chains and Due Diligence Processes 

3.1 Disguise Technologies expects our suppliers to adopt the same high standards that we adhere to including having fair employment practices. This is reflected in our sustainable procurement practices and the conduct required by our Business Ethics Policy with which we expect our suppliers to comply. The Ethics Policy specifically requires, amongst other things, that our suppliers ensure their employment is freely chosen, child labour shall not be used, living wages are paid and working hours are not excessive.

3.2 Our principal third party suppliers are businesses which supply services related to the running of our business including partner agencies working on site at events. 

3.3 To initiate the process of identifying and assessing any actual or potential involvement in modern slavery in our supply chain we have categorised suppliers according to factors that might indicate a high risk of modern slavery, including the location from which services are provided or goods are manufactured and the sectors or activities which present a high risk of modern slavery. To do this we have sought to involve meaningful consultation with relevant stakeholders. We have applied this method to supplier data captured by our Finance team and will continue to build on this to gain further visibility into our supply chain. 

3.4 Key suppliers to Disguise Technologies submit information about themselves in answer to which questions which assess a commitment to operating a fair and ethical workplace and identifying potential issues relating to modern slavery. We use this data to assess risk and inform decisions when selecting suppliers. We review our supplier list on an annual basis. 

3.5 Our standard contract terms contain a clause by which suppliers commit to respecting and supporting international human rights and undertake that they will comply with their obligations under the Modern Slavery Act or any other similar legislation. We also reserve the right to terminate agreements with immediate effect where the supplier commits a material breach. Breach of the clause dealing with modern slavery is separately identified as grounds for termination. 

Performance Indicators 

4.1. We have identified that the parts of our business and supply chain that carry a potential risk of modern slavery are predominantly those which involve smaller suppliers providing goods and services outside the UK. The steps we are taking to assess and manage these risks are outlined in this statement. 

4.2 Our Operations team representatives formally meet with each of our key suppliers at least annually. The frequency of these meetings is dictated by a number of factors, including consideration of the risks posed by involvement in modern slavery. Our standard contract terms contain a contractual right to audit our suppliers. 

Our Policies 

5.1. Disguise Technologies is committed to being a responsible business. We are explicitly committed to the United Nations’ Guiding Principles on Business and Human Rights. This Policy confirms our commitment to respect and support international human rights, and in particular, to the International Bill of Rights and the International Labour Organisation's Declaration on the Fundamental Principles and Rights at Work.

5.2 We comply with all applicable employment law relating to employee, worker and contractor terms and conditions, including pay as articulated in our Employee, Workers & Contractors Policy. disguise technologies is committed to the following core values in connection with our people: 

  • we value diversity and respect for the individual; 

  • we believe in teamwork for the good of the company and our clients; and 

  • we believe in the development of all our people and rewarding achievement fairly. 

5.3 The People Strategy articulates our commitment to develop the capability of our people and help them to realise their potential by achieving a consistently high standard in managing, training and supporting Disguisers and developing their careers. 

5.4 Other policies which contribute to and support our approach to the identification and prevention of modern slavery in our business include : 

  • Equality & Diversity Policy: Encourages all our people to value diversity and respect each person's individuality, and to ensure that no partner, employee, agency worker, contractor, self-employed consultant, job applicant or ex-employee, client or third party receives less favourable treatment on the basis of colour, race, nationality, ethnic or national origins, sexuality or gender, disability age nor religion or belief. 
     

  • Whistleblowing Policy: Offers individuals a confidential mechanism for disclosing suspicions or knowledge of possible impropriety to protect the company, its brand, people and clients by delivering an early warning when something goes wrong. This includes matters pertaining to our supply chain which would include modern slavery. 
     

  • Anti-bribery Policy: Setting out the company's rules and what is expected of all our people, we expect the same standard of conduct to the company's contractors and third party service providers in all dealings with us on our behalf. 

Training 

6.1. In relation to modern slavery, we have begun integrating findings from our assessment, referenced above, across internal functions and processes. This includes raising awareness and understanding of potential risks and how to manage those risks across relevant business functions. 

6.2 We exceed the £36m turnover threshold which requires us to take action under the Modern Slavery Act, and therefore ensure that all employees undertake training around modern slavery on our E-learning platform annually. A number of modules around compliance and awareness must be completed during the induction and on-boarding period of all employees and by those Contractors or Consultants who will be engaged by the Company for 3 months or longer. These modules include: Prevention and Awareness of Modern Slavery, Anti-Bribery, GDPR, Equality & Diversity, Whistle-Blowing & Health & Safety. All policies are shared with employees on the People Portal and employees are required to refresh themselves on these annually.

Responsible Business 

7.1. At Disguise Technologies we are committed to contributing to the wellbeing of communities around the world. We encourage our employees to be mindful of our company values and operating standards as they conduct their work around the world and work with international communities. 

7.2 Disguise Technologies is committed to acting within the spirit of United Nations Global Compact (UNGC) and its ten universal principles around human rights, labour practices, environment and anti-corruption. 

7.3 Our ESG Policy includes regular charitable giving and fundraising to our chosen charities on a per-year basis. Employees are encouraged to spend one company-paid day a year to volunteer for not-for-profit causes. In addition, employees are encouraged to take paid time off to regularly donate blood if it is possible for them to do so. 

7.4 Having a strong commitment to ESG subjects and impacts including fair Business practices is fundamental to how our company operates.