Modern slavery and human trafficking statement

1. Status of this statement

This statement is published voluntarily by United National Photographers Ltd with reference to the transparency principles set out in section 54 of the Modern Slavery Act 2015.

It describes the approach taken by UNP to prevent modern slavery and human trafficking within its operations and supply chains. It is intended to support transparency for clients, procurement teams, photographers, suppliers and other organisations working with us.

2. Our commitment

Modern slavery is a serious crime and a violation of fundamental human rights. It can include slavery, servitude, forced or compulsory labour, child labour and human trafficking, involving the deprivation of a person’s liberty for personal or commercial exploitation.

UNP has a zero-tolerance approach to modern slavery and human trafficking. We do not knowingly tolerate such practices within our operations or supply chains.

We are committed to conducting our business ethically, transparently and with integrity, and to maintaining proportionate systems and controls intended to identify and address relevant risks.

3. About United National Photographers

United National Photographers Ltd is a specialist photography agency and central Picture Desk. The company is registered in England and Wales under company number 04253192.

UNP coordinates professional photography services including press, public-relations, corporate, event, editorial, healthcare, education, retail and multi-location assignments for clients in the commercial, media, public and not-for-profit sectors.

Our central Picture Desk is based in the United Kingdom. We work with a nationwide network of professional freelance photographers, along with selected videographers, drone operators, assistants, editors and specialist suppliers.

4. Our supply chains

UNP’s supply chains principally support the coordination, production, delivery and administration of professional photography assignments.

Our direct freelance and professional-services relationships are predominantly UK-based. However, some equipment, technology, software and indirectly sourced products may involve international manufacturing or multi-tier supply chains.

5. Risk assessment

We assess modern-slavery risk proportionately, taking into account the nature of the service, location, workforce model, level of subcontracting and visibility of the supply chain.

Factors that may indicate a higher level of risk include:

• extensive or unexplained subcontracting;
• labour-intensive services supplied through multiple intermediaries;
• work undertaken in jurisdictions associated with weak labour protections;
• unusually low pricing that may indicate unfair working practices;
• restrictions on workers’ freedom of movement or access to identification documents;
• signs of coercion, intimidation, unsafe working conditions or withheld pay;
• the use of child labour, forced labour or involuntary labour; and
• suppliers unwilling to provide reasonable information about their employment or sourcing practices.

UNP’s direct photography network is made up primarily of established professional freelancers supplying skilled services. We nevertheless recognise that risk may arise elsewhere within wider travel, technology, hospitality, manufacturing and support-service supply chains.

6. Policies and governance

Our approach to modern slavery is supported by wider policies, procedures and business controls relating to ethical conduct, supplier engagement and the treatment of people working with UNP.

• ethical conduct and professional standards;
• freelance photographer and supplier engagement procedures;
• equality, dignity and non-discrimination expectations;
• safeguarding and responsible assignment management;
• confidential reporting and escalation of concerns;
• contractual and procurement controls; and
• periodic review of significant supplier relationships.

Relevant expectations may be communicated through agreements, assignment instructions, procurement discussions and ongoing supplier-management processes.

7. Due diligence

UNP applies proportionate due diligence when engaging photographers, contractors and suppliers, with additional scrutiny where the nature or location of a service presents an increased risk.

1. Understand the supplier We establish the identity, role, experience and operating location of significant photographers, contractors and service providers.
2. Assess relevant risk We consider the nature of the service, workforce arrangements, subcontracting, geography and available information about working practices.
3. Communicate expectations We expect suppliers to comply with applicable employment and human-rights laws and not to use forced, trafficked or child labour.
4. Request further information Where a heightened risk is identified, we may request policies, declarations, supporting information or clarification about the supplier’s own supply chain.
5. Take appropriate action Where concerns cannot be resolved satisfactorily, action may include further investigation, corrective requirements, suspension of work or termination of the relationship.

8. Supplier standards

UNP seeks to work with suppliers, contractors and freelance photographers who share our commitment to ethical conduct and lawful working practices.

We expect relevant suppliers to:

• comply with applicable modern-slavery, employment, equality and human-rights legislation;
• provide workers with lawful terms, appropriate remuneration and safe working conditions;
• not use forced, bonded, trafficked, involuntary or child labour;
• not retain workers’ identification documents or restrict their freedom unlawfully;
• apply reasonable oversight to their own contractors and supply chains;
• raise concerns promptly where exploitation is identified or suspected; and
• cooperate with reasonable enquiries made by UNP about relevant risks.

UNP may incorporate modern-slavery expectations into appropriate supplier terms, freelance agreements, procurement requirements or client-specific assignment arrangements.

9. Training and awareness

Guidance may be provided to relevant members of the Picture Desk and others involved in supplier engagement, assignment planning or procurement.

Training and awareness activity may cover:

• the meaning and principal forms of modern slavery;
• how exploitation may appear within service-based, freelance and subcontracted work;
• warning signs that may require further enquiry;
• responsible engagement of freelancers and suppliers;
• how to document and escalate a concern; and
• the importance of protecting people who raise concerns in good faith.

Training content and internal guidance are reviewed periodically and may be updated to reflect changes in legislation, procurement expectations and recognised good practice.

10. Measuring effectiveness

We use proportionate measures to review whether our policies and controls remain appropriate for the size and nature of the business.

We will continue to develop our approach as our supplier relationships, client requirements and understanding of modern-slavery risks evolve.

11. Reporting concerns

Anyone working with or on behalf of UNP who becomes aware of suspected modern slavery, forced labour, child labour, human trafficking or related exploitation is encouraged to report the concern promptly.

Reports will be taken seriously and reviewed appropriately. Information should be provided in good faith and should include enough detail to help us understand the concern without placing the person reporting it at unnecessary risk.

12. Approval and review

This statement has been reviewed on behalf of United National Photographers Ltd and will be reconsidered periodically as the company’s operations, supplier relationships and governance requirements develop.

Signed for United National Photographers Ltd by

Hamlet Mejloumian, Director

Original statement approval date

25 June 2025

Current version reviewed

3 August 2026

Further guidance

• Modern Slavery Act 2015 — section 54
• GOV.UK guidance on modern slavery statements
• UK Government modern slavery resources
• International Labour Organization

Related governance documents