Thursday , 25 July 2024

Modern Slavery Act Statement


This statement is published in line with the Modern Slavery Act 2015 and outlines the actions taken by and its group companies during the financial year ending December 31, 2021, to combat modern slavery and human trafficking within its operations and supply chains. is dedicated to ensuring that our operations and supply chains are free from modern slavery and human trafficking, recognizing these as grave violations of human rights.

Our Business and Structure is a leading digital news platform, producing and distributing content globally. Our operations include news reporting, digital content creation, and multimedia production. We engage with a diverse workforce, including full-time employees, freelancers, and contributors across the globe, to deliver high-quality news content.

Our supply chains

Our supply chains primarily consist of:

We prioritize partnerships with suppliers in regions with robust legal frameworks against modern slavery, primarily in Europe and North America.

Our policies on slavery and human trafficking is committed to a zero-tolerance approach to modern slavery and human trafficking. We uphold this commitment through our Global Conduct Policy and a specific Modern Slavery and Human Trafficking Policy, ensuring ethical practices across our business and supply chains.

Supplier adherence to our values

We have zero tolerance for slavery and human trafficking. We have a dedicated Procurement Services team that works closely with our Legal, Compliance, and Internal Audit teams.

We have a Global Procurement Policy in place to ensure a controlled, transparent, auditable, and compliant procurement service, and which is approved by our Chief Financial Officer. Our staff is required to complete appropriate due diligence analysis to ensure that prospective suppliers are qualified to conduct business with FrontPage News Media.

Our Group Procurement team takes supplier management and performance seriously.Decisions on potential suppliers are taken based not only on price and delivery times, but other factors including the supplier’s ability to deliver while maintaining compliance with applicable laws and, where the supplier has previously been engaged by us, past compliance with FrontPage News Media’s standards. Group Procurement monitors contractual performance by our suppliers and implements Continued Improvement Programmes (CIPs) with our suppliers where applicable.

Wherever possible we seek to procure goods and services from an existing supplier already known to FrontPage Group, which allows us to better understand our suppliers’ operations and policies and to build strategic, long-term relationships with those suppliers.

To ensure all those in our supply chain and contractors comply with our values, we have a rigorous supply chain compliance program in place. This currently consists of the following measures:

Risk assessment

During 2020, we have continued to assess our business and supply chains to identify any particular sectors or geographies where a greater risk of modern slavery or human trafficking may occur and have sought to identify what measures are in place to mitigate those risks. For example:

In 2020, we conducted an extensive Modern Slavery Audit across 91 of our largest and most critical suppliers (Tier 1-3). This assessment included validation of Modern Slavery prevention processes in place and, where applicable, the further completion of the FrontPage News Modern Slavery Questionnaire. No suppliers were removed from our pool of suppliers as a result of this audit, and no material concerns were raised.

In addition, in 2020, we commenced the roll-out of our Environmental, Social, and Governance Questionnaire to be completed as part of our supplier onboarding procedures. This includes the requirement for the supplier to identify and document Modern Slavery prevention practices in place throughout its businesses and wider supply chain. This will identify what systems and controls the supplier has in place to ensure slavery and trafficking are not taking place in any part of their business.

Training and compliance

All FrontPage News staff are required to read, understand, and commit to following our Global Conduct Policy. Members of senior management receive specific face-to-face training on the topic of Conduct and Ethics, referring to our Global Conduct Policy in order to promote proper Conduct and Ethics practices throughout our organization.

All FrontPage News staff involved in the procurement of global goods and services are required to comply with our Procurement Policy.


FrontPage News has in place a global Whistleblowing Policy, which includes detailed whistle-blowing guidance to enable and encourage all staff to express concerns regarding any misconduct or wrongdoing related to our business. This may be done either by raising aconcern internally, anonymously through our external whistleblowing channel, or by raising a concern directly to our designated Whistleblowing Champion if that member of staff prefers to speak to someone outside the operational business. All reports will be investigated and appropriate remedial actions are taken. FrontPage News has a zero-tolerance policy to retaliation and will always maintain the whistleblower’s confidentiality, to the extent permitted by law. All staff is required to periodically complete an online training module that highlights these procedures.

Our effectiveness in combating slavery and human trafficking

In order to assess the effectiveness of the measures taken by FrontPage News in combating modern slavery and human trafficking during 2020, we used the following key performance indicators (“KPIs”). The table below sets out the results of our monitoring of these KPIs and the actions taken to address any issues raised.


The proportion of FrontPage Group staff who have completed relevant training or have otherwise confirmed in writing their agreement to the relevant policies and procedures


The percentage of whistleblowing reports made related to slavery or human trafficking incidents.


The remedial actions are taken in response to any investigations into reports of modern slavery or human trafficking.


The number of audits of higher-risk suppliers carried out by our Procurement Services team and any remedial actions taken.

Results and Actions Taken

New joiners are required to complete the relevant training and confirm their agreement to the relevant policies and procedures within 14 days of joining FrontPage News. During 2020, 99% of new joiners had successfully done so and any cases of non-compliance were escalated to management and pursued until the training had been successfully completed.

Existing staff are also required to complete refresher training annually. Any cases of non-compliance in 2020 were escalated to management and pursued until the refresher training had been successfully completed.

No whistleblowing reports relating to slavery or human trafficking incidents were received.

No such reports were received.

We audited 91 of our largest and most critical suppliers across all Business Units and geographies. No remedial actions were necessary (e.g., no suppliers were removed from our pool of suppliers) because of these audits as no material concerns were raised.

We continue to assess these KPIs each year to consider whether alternative or additional KPIs would be most appropriate in order to measure the effectiveness of our actions.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes FrontPage Group’s slavery and human trafficking statement for the financial year ended 31 December 2020.

This statement has been approved by the boards of directors of FrontPage Group Holdings Limited, FrontPage Financial Services Limited, Prepaid Services Company Limited, Skrill Limited, FrontPage News Payment Solutions Limited, and FrontPage Prepaid Services Limited.

Signed by

Dean Rich
Executive Editor
FrontPage News Media S.L