Modern Slavery Statement 2025
Introduction
This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and sets out the steps TOPPAN Digital Language Ltd (the “Company”) has taken, and continues to take, to ensure that modern slavery and human trafficking are not occurring in our operations or supply chains. TOPPAN Digital Language is committed to acting ethically and with integrity in all our business dealings and to implementing effective systems and controls to prevent modern slavery.
Organisational Structure and Operations
TOPPAN Digital Language Ltd is a private limited company and subsidiary of TOPPAN Holdings Inc., operating in the Language Services sector. The Company is headquartered in London, United Kingdom, with operations in the UK, the European Union, the United States of America, Hong Kong, China and South Korea. Our global workforce consists of approximately 320 employees, and we work with a diverse network of suppliers and partners to deliver our professional services.
The TOPPAN Digital Language group of companies’ annual turnover exceeds £36 million, and as such, we are required to publish this statement under the Modern Slavery Act 2015. This statement is for the financial year ending 31 March 2026 and covers TOPPAN Digital Language Ltd and its subsidiaries:
TOPPAN Digital Language (UK) Ltd
TOPPAN Digital Language (APAC) Ltd
TOPPAN Digital Language GmbH
TOPPAN Digital Language, Spain S.L
TOPPAN Digital Language (Americas) LLC
TOPPAN Digital Language (Poland) sp zoo
TOPPAN Digital Language (Asia) Ltd
TOPPAN Digital Language (China) Co., Ltd.
Our Supply Chains
The Company is a provider of language services, such as translation and interpreting services. In providing these services, the Company works with agencies and freelance professionals in many countries around the world. We recognise that certain countries where we engage these suppliers may carry a higher risk of modern slavery. However, it is the view of the Directors that the nature of our services and the industry we operate in presents a low risk of modern slavery. Factors impacting this risk profile include short supply chains, no manual labour or production of physical goods, and a requirement for professional qualifications.
Policies on Modern Slavery
TOPPAN Digital Language has implemented the following policies to address modern slavery and human trafficking:
- TOPPAN Conduct Guidelines: this code of conduct outlines our commitment to preventing modern slavery and human trafficking in our operations and supply chains, with clear expectations for employees, suppliers, and partners.
- Supplier Service Agreements: we require all suppliers to comply with applicable laws, including those related to modern slavery, and to uphold ethical labour practices.
- Whistleblowing Policy: we encourage employees and stakeholders to report concerns about modern slavery or unethical practices confidentially, with protections against retaliation.
- Human Resources Policies: we ensure fair recruitment practices, including verification of workers’ eligibility to work and prohibition of forced or child labour.
These policies are reviewed regularly to ensure they remain effective and aligned with best practices.
Due Diligence Processes
To identify and mitigate modern slavery risks, we have implemented the following due diligence measures:
- Supplier Assessments: We conduct risk-based assessments of new and existing suppliers through questionnaires and interviews
- Contractual Obligations: Our supplier contracts include clauses requiring compliance with the Modern Slavery Act 2015 and ethical and legal conduct
- Audits and Monitoring: We reserve the right to carry out periodic audits of suppliers, either directly or through third-party auditors, to verify compliance with our standards.
- Training: We provide training to employees in HR, procurement and supply chain roles, to recognise signs of modern slavery and understand our due diligence processes.
Steps Taken in the Past Year
During the past twelve months, we have taken the following actions to strengthen our approach to preventing modern slavery:
- Conducted a risk assessment of our supply chains
- Developed our Modern Slavery Statement, policy and training.
Future Commitments
In the current year, TOPPAN Digital Language commits to:
- Increasing employee training to ensure all relevant staff are trained on modern slavery risks.
- Developing a policy of supplier audits for suppliers in high-risk locations.
- Enhancing our risk assessment tools to better identify vulnerabilities in our supply chain.
Approval
This statement has been approved by the Directors of TOPPAN Digital Language Ltd and will be reviewed and updated annually. It is available on our website at www.toppandigital.com/modern-slavery-statement
Signed:
Alexandra Jarvis
Director
6 June 2025