Cream Global Limited

Modern Slavery Policy 2024

Our Policy Statement

We, at Cream, recognise that slavery and human trafficking remain a blight on today’s society. We have a zero tolerance approach to modern slavery and we are committed to working ethically and with integrity in all our business relationships. We are dedicated to implementing and enforcing controls to ensure that all individuals are treated with dignity and respect to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Our commitment to doing everything we can to combat modern slavery means we all have an obligation to ensure legal compliance, uphold ethical standards, and combat human rights violations. We expect everyone in our supply chain to adopt the same high standards. To ensure compliance, and as part of our contracting processes, we require that the following clause be included in our supply contracts:

“[Third party] warrants and undertakes to Cream Global Limited that it:

       i.         will not engage in any activity, practice, or conduct which would constitute an offence under the Modern Slavery Act 2015; and

     ii.         has and will maintain in place adequate procedures, as referred to in the Modern Slavery Act 2015 and any guidance issued by the Secretary of State, designed to prevent any person (including an employee, agent, subsidiary, supplier or sub-contractor) who performs services or provides goods for or on its behalf from undertaking any conduct that would give rise to an offence under the Modern Slavery Act 2015.”

This policy applies to all persons working for us or on our behalf in any capacity, including all our employees, directors, volunteers, agents, contractors, consultants, suppliers, and business partners.

Responsibility for Our Policy

The board of directors has the overall responsibility of ensuring our compliance with all legal and ethical obligations, and for ensuring that all those in the business comply with this policy.

The Global Ethics & Compliance Department has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, and dealing with any queries related to it. The Global Internal Audit Group will monitor the effectiveness of the internal control systems and procedures. 

Management at all levels is responsible for ensuring that their teams understand and comply with this policy and are given access to suitable and regular training, when necessary.

We recognise that the prevention, detection, and reporting of modern slavery is our collective responsibility.

Individuals 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 Global Ethics & Compliance Department via compliance@livenation.com.

Compliance with Our Policy

All persons working for us or on our behalf must read, understand, and comply with this policy and avoid anything that might lead to a breach of it.

If individuals have concerns or suspicions of modern slavery in  any part of our business and/or they believe or suspect a breach of this policy has occurred or may occur, they are encouraged to notify their manager and/or human resources and/or report it directly to the Global Ethics & Compliance Department at compliance@livenation.com as soon as possible.

If individuals are unsure whether a particular activity constitutes a breach of this policy, this should be raised with their manager. We continually 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 as a result of reporting, in good faith, their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If individuals believe that they have suffered any such treatment, they should inform the Global Ethics & Compliance department immediately via compliance@livenation.com or through our Employee Business Integrity Hotline at www.livenation.ethicspoint.com or via phone at UK: 0808-234-1231.

Communication and Awareness of Our Policy

We have provided training on this policy to all employees who are deemed to be working in areas of the business that may be exposed to the risk of modern slavery and trafficking. We will continue to provide this training to the relevant employees.

All staff involved with engaging third parties on behalf of the business must communicate our zero tolerance approach at the outset of any business relationship and reinforce our approach as appropriate thereafter.

Breaches of Our Policy

We may terminate our relationship with third parties working with us or on our behalf if they fail to comply with our policy.

This policy does not form part of any employee’s contract of employment and we may amend it at any time. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

 

Managing Director

 

Date: June 2024