1.1. PURPOSE

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LUNA TIDES is committed to acting ethically, with integrity and transparency in all areas of our business. We recognise our responsibility to help prevent modern slavery, human trafficking, forced labour and exploitation within our operations and wider supply chain. The purpose of this policy is to set out our commitment to identifying, preventing and responding to risks of modern slavery and human trafficking. It also supports a culture of responsible business practice and due diligence across our projects, partnerships and supplier relationships.

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We recognise that while the risk of modern slavery within our business may be relatively low, no sector or supply chain is entirely free from risk. We are committed to taking proportionate steps to identify and address risks wherever they arise.

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1.2. SCOPE

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This policy applies to all individuals working for or on behalf of LUNA TIDES, including employees, freelancers, contractors, collaborators, suppliers and production partners. It applies across all areas of our business, including recruitment and engagement, procurement and supplier relationships, project delivery, freelance and contractor management and location-based production activity.

2.1. Commitment to Compliance

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LUNA TIDES is committed to complying with all relevant UK legislation relating to modern slavery and human trafficking, including the Modern Slavery Act 2015.

 

We will not knowingly engage in, support or tolerate any form of:

 

• Forced labour

• Bonded labour

• Human trafficking

• Child labour

• Exploitative working practices

• Coercion, abuse or intimidation
   

 

We recognise that preventing modern slavery is not limited to legal compliance. It also requires transparency, good working practices and ongoing awareness of risk. We are committed to taking proportionate steps to identify and reduce the risk of exploitation in all areas of our operations.

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2.2. Responsible Business Practices

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We recognise that ethical business practices, fair treatment and responsible working relationships are key to reducing the risk of exploitation.

 

As part of our day-to-day operations, we are committed to:

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• Acting transparently and fairly in our working relationships

• Treating individuals with dignity and respect

• Promoting fair pay and clear expectations

• Supporting safe and lawful working conditions

• Avoiding unreasonable demands or practices that could create exploitation risks
   

 

As a production business working with freelancers, suppliers and external partners, we recognise the importance of maintaining clear communication, fair engagement and professional standards throughout projects and business relationships. We are committed to fostering working relationships based on trust, professionalism and respect and to avoiding any practices that could contribute to unsafe, unfair or exploitative conditions.

3.1. Risk Awareness

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We recognise that modern slavery risks can arise in supply chains, freelance engagement, location-based activity and third-party services, even in sectors where overall risk may appear lower. As a production business, potential risks may arise through:

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• External suppliers and service providers

• Equipment hire and logistics companies

• Location services and site support

• Freelance labour and subcontracting

• Production support and temporary staffing

We are committed to maintaining awareness of these risks and considering them as part of our wider business operations, project planning and supplier relationships. Although we consider our direct risk to be relatively low, we recognise the importance of remaining alert to potential warning signs and taking concerns seriously.

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3.2. Due Diligence

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LUNA TIDES will take reasonable and proportionate steps to assess and manage modern slavery risks within our operations and wider supply chain.

 

This may include:
 

• Working with reputable suppliers, freelancers and partners

• Using clear contracts, briefs and terms of engagement

• Checking that suppliers and contractors operate lawfully and responsibly

• Maintaining oversight of working practices and delivery arrangements

• Raising questions where practices appear unclear or inappropriate

​Our due diligence approach will be proportionate to the nature, scale and level of risk associated with each engagement. We recognise that due diligence is an ongoing process and are committed to maintaining practical oversight of how work is delivered and who we work with.

4.1. Fair Recruitment

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We are committed to fair, lawful and transparent recruitment and engagement practices. We believe that clear communication and fair treatment from the outset are important in reducing the risk of exploitation.

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This includes:

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• Using clear and transparent recruitment and engagement processes

• Ensuring individuals understand the nature and terms of their work

• Providing clear expectations around duties, pay, timescales and working arrangements

• Avoiding misleading, coercive or exploitative practices
   

 

We are committed to ensuring that individuals engaged by LUNA TIDES understand their role, rights and expectations and are treated fairly throughout their work with us.

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4.2. Freelancers, Contractors & Production Partners

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As a business that regularly works with freelancers, contractors and production partners, we recognise the importance of ensuring that all individuals are treated fairly and engaged responsibly.

We are committed to:
 

• Providing clear briefs and expectations

• Agreeing fair payment arrangements

• Maintaining safe and respectful working environments

• Setting reasonable working expectations

• Communicating professionally throughout projects

 

This helps us maintain ethical working relationships and reduces the risk of exploitative practices within our wider delivery model. We also recognise the importance of working with production partners and suppliers who share similar values around fair treatment, safety and responsible working practices.

5.1. Raising Concerns

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We encourage anyone working with or on behalf of LUNA TIDES to raise concerns if they suspect modern slavery, human trafficking, forced labour or exploitation.

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Concerns may relate to:

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• Unsafe or abusive working conditions

• Signs of coercion or control

• Unfair or withheld pay

• Restriction of movement or communication

• Suspicious behaviour within supply chains or working relationships
   

 

Concerns may be raised through management, the Whistleblowing Policy, the Safeguarding Policy or another appropriate reporting route. We recognise that raising concerns can feel difficult and are committed to creating an environment where individuals feel able to speak up without fear of unfair treatment.

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5.2. Response & Action

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Where concerns are raised, we will review the issue promptly, sensitively and in a proportionate manner. Depending on the nature and seriousness of the concern, this may include:

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• Reviewing the issue internally

• Gathering further information

• Taking steps to protect individuals at risk

• Pausing or reviewing supplier, contractor or project arrangements

• Escalating concerns to external authorities where required
   

 

The safety, wellbeing and protection of individuals affected will always be a key priority. Our aim is to ensure that concerns are addressed responsibly and that appropriate action is taken to reduce risk and prevent harm.

6.1. Shared Responsibility

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Preventing modern slavery and labour exploitation is a shared responsibility across LUNA TIDES. While the level of responsibility may vary depending on role, everyone working with or on behalf of the business has a part to play in supporting ethical and responsible working practices.
 

 

All employees, freelancers, contractors, collaborators and others engaged by LUNA TIDES are expected to:
 

 

• Act ethically, responsibly and in line with this policy

• Treat others fairly, respectfully and professionally

• Remain alert to signs of exploitation, coercion, unsafe conditions or unfair treatment

• Raise concerns where something appears inappropriate or causes concern

• Support a culture of openness, accountability and safe working
  
   

• 6.2. Management Responsibility
   

Management is responsible for promoting awareness of this policy and ensuring that ethical working practices are embedded across the business.

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This includes:

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• Leading by example in relation to ethical conduct and fair treatment

• Considering modern slavery risks when selecting suppliers, freelancers, contractors and partners

• Maintaining oversight of working practices and delivery arrangements

• Supporting fair recruitment, onboarding and engagement processes

• Ensuring that concerns are taken seriously and reviewed appropriately

• Taking proportionate action where risks or issues are identified

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Management is also responsible for fostering a culture where individuals feel able to raise concerns without fear of unfair treatment or retaliation. As part of our wider governance approach, management will review working practices, supplier relationships and delivery models where relevant to help identify areas for improvement and reduce the risk of exploitation.

7.1. Policy Review

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LUNA TIDES will review this policy periodically to ensure that it remains relevant, practical and aligned with current legal requirements and recognised good practice. As our business evolves, we recognise the importance of ensuring that our approach to preventing modern slavery remains appropriate to the nature and scale of our operations.

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Reviews may take into account changes in legislation or guidance, business growth, changes to our delivery model, supply chain developments and any lessons learned from concerns raised or issues identified. This helps ensure that the policy remains effective, proportionate and fit for purpose.

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7.2. Continuous Improvement

 

We are committed to reviewing our working practices over time and making improvements where appropriate to strengthen awareness, due diligence and ethical standards across the business. This may include reviewing supplier and engagement practices, improving oversight of working arrangements, strengthening internal awareness and updating processes where risks or opportunities for improvement are identified.

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Where appropriate, LUNA TIDES will also ensure that individuals involved in recruitment, supplier engagement, project management and wider operations are made aware of the principles set out in this policy. This may include internal guidance, onboarding information or practical discussions to help recognise potential risks and support responsible working practices.

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Our aim is to maintain a practical and proportionate approach to preventing modern slavery and to support a culture of transparency, accountability and responsible business practice across all areas of LUNA TIDES.

This policy should be read alongside other LUNA TIDES policies and procedures that support ethical conduct, fair treatment and safe working.

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These may include:

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• Whistleblowing Policy

• Safeguarding Policy

• Diversity, Equity and Inclusion Policy

• Health and Safety Policy

• Sustainability Policy
   

 

Together, these policies help support a responsible, transparent and ethical approach across all areas of our business.

If any person who falls under the scope of this policy (outlined in Section 2.2.) suspects modern slavery in our supply chains, they should:

 

• Report concerns immediately to the Managing Director

 

We will then report immediately to the local police via 999 and contact the Modern Slavery Helpline on 0800 0121 700.

 

If any person who falls under the scope of this policy (outlined in Section 2.2.) suspects modern slavery in our business practices, their options for reporting are as follows:

 

• Reporting to the local police via 999

• Contact the Modern Slavery Helpline on 0800 0121 700 (particularly if they hold information on the identification, discovery, and recovery of victims in the UK)

• Anonymously calling Crimestoppers on 0800 555 111

 

For more information on modern slavery, all individuals under the scope of this policy are advised to visit www.unseenuk.org.