1. Purpose
White Space Agency is committed to respecting the human rights of all individuals across our operations and business relationships in line with international frameworks and standards for responsible business conduct, including the United Nations Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, and the International Labour Organisation Declaration on Fundamental Principles and Rights at Work.
2. Scope
This policy applies to White Space Agency’s own operations and workforce, and extends to the business relationships through which it creates and delivers work for clients, including the selection of clients and projects, and decisions about the suppliers and services it engages to deliver that work.
Human rights considerations are integrated into two key areas of business activity: the screening of potential organisational clients and projects before engagement, and procurement decisions about the suppliers and services White Space Agency uses. A risk-based approach is applied, with attention focused on situations where the likelihood or severity of negative impacts on people is greatest.
Where differences exist between national legislation and internationally recognised human rights standards, White Space Agency will meet local legal requirements while seeking to uphold the principles of this policy.
3. Commitments
White Space Agency publicly commits to respect human rights across its operations and business relationships, in line with the following internationally recognised frameworks:
• The United Nations Guiding Principles on Business and Human Rights (UNGPs)
• The International Bill of Human Rights, including the Universal Declaration of Human Rights (UDHR)
• The International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work, including the elimination of forced and compulsory labour, the abolition of child labour, the elimination of discrimination in employment, and freedom of association and the right to collective bargaining
These commitments are implemented in a manner proportional to the size and nature of White Space Agency’s business and value chain.
4. Principles
White Space Agency’s approach is guided by the following principles.
4.1 Respect for human rights
White Space Agency respects internationally recognised human rights and meets its responsibility to respect human rights across its operations and business relationships through which it creates and delivers its services.
4.2 Equal treatment and non-discrimination
White Space Agency does not tolerate discrimination in employment or work, including in recruitment, pay, training, promotion, and termination. This expectation extends to the contractors and suppliers it engages.
4.3 Forced labour and modern slavery
White Space Agency prohibits forced labour and human trafficking in any part of its operations or supply chain. Any indicator of forced labour is treated as a high-severity concern requiring immediate escalation.
4.4 Child labour and young workers
White Space Agency prohibits child labour. No person shall be employed under the age of 15, or under the age for completion of compulsory education, whichever is higher. Young workers aged 15 to 17 must not perform work that could compromise their health, safety, or development.
4.5 Safe and healthy work
White Space Agency expects working conditions that protect health and safety, including for any contractors or freelancers engaged to deliver its services.
4.6 Freedom of association
White Space Agency respects workers’ rights to organise and bargain collectively in line with international standards.
5. Client and Project Screening
Before engaging with a new organisational client or commencing a significant new project, White Space Agency assesses the potential negative human rights impacts of that engagement.
The screening process considers the sector and activities of the client, the nature of the project, and any indicators that the engagement could contribute to or be linked to negative human rights impacts. Where potential impacts are identified, mitigation actions are determined before the engagement proceeds.
6. Procurement
White Space Agency integrates human rights considerations into its procurement decisions, including the selection of suppliers, contractors, freelancers, and service providers used to deliver its work. This process is set out in the Procurement Impact Assessment, which is maintained as a companion document to this policy.
Procurement decisions are assessed for potential human rights impacts using a risk-based approach that considers the severity and likelihood of harm. Records of assessments for the most material procurement decisions each year are retained.
7. Reporting concerns and remediation
White Space Agency encourages concerns related to human rights, worker welfare, or negative social impacts to be raised without fear of retaliation. Concerns may be reported to any Director and will be handled in a confidential and proportionate manner.
Where White Space Agency has caused or contributed to an adverse impact, it will seek to provide or cooperate in a remedy. In cases of severe or persistent violations connected to a business relationship, White Space Agency may suspend or end that relationship.
8. Roles and Responsibilities
Directors are responsible for approving this policy, maintaining oversight of human rights risks and outcomes, and making escalation decisions in higher-severity cases. All employees are expected to carry out their work in a way consistent with this policy, and to raise any concerns with a Director.
9. Review
This policy is reviewed annually, or where significant changes occur to White Space Agency’s operations or business relationships, to ensure it remains appropriate and up to date.