Our commitment
Sternberg Consulting does not tolerate modern slavery, forced labour, child labour, or human trafficking. We expect comparable standards from business partners, suppliers, and subcontractors.
Although Sternberg Consulting has a low inherent risk profile as a consulting business, we take human rights, fair working conditions, and responsible supply chains seriously. This policy explains how risks are identified, assessed, and addressed.
Scope
This policy applies to our consulting activities, selection of service providers, and cooperation with external partners.
It applies to all people and organisations providing services for or on behalf of Sternberg Consulting, including freelancers, subcontractors, service providers, suppliers, and cooperation partners.
Definitions
Modern slavery includes forced labour, debt bondage, human trafficking, exploitation, unlawful restriction of movement, retention of identity documents, exploitative child labour, and comparable forms of serious labour rights abuse.
Risk profile
Our work consists mainly of consulting, audit, training, and documentation services. Direct risks in our own service delivery are therefore limited. Elevated risks may arise with external service providers, international supply chains, digital platforms, procurement of goods, or client projects involving complex supply chains.
Due diligence
- We prefer to work with reputable and transparent service providers.
- When engaging new business partners, we consider visible risks relating to exploitation and forced labour.
- We review or end business relationships where substantial indications of violations exist.
Where risk is elevated, additional checks may be carried out, for example through self-disclosures, contractual clauses, reference checks, or requests for suitable evidence.
Expectations of business partners
Business partners must comply with applicable labour law, ensure fair working conditions, pay wages lawfully, observe working time rules, and must not use or support any form of forced labour, human trafficking, or exploitative child labour.
We also expect business partners to take substantiated concerns seriously, investigate them appropriately, and implement corrective action.
Procurement and suppliers
When selecting suppliers, we consider integrity, transparency, and visible social risks alongside quality, price, and reliability. Where indicators of elevated risk exist, we may request additional information or decide not to cooperate.
Remediation and action
If a concern about modern slavery, forced labour, or human trafficking arises, we review the matter appropriately. Possible actions include clarification with the business partner, requirements for corrective action, suspension of cooperation, contract termination, or notification of competent authorities.
Training and awareness
People acting on behalf of Sternberg Consulting should understand typical warning signs, such as unusual payment routes, lack of transparency about subcontractors, concerning working conditions, or indications that documents are being withheld.
Reporting concerns
Concerns relating to modern slavery, forced labour, or human trafficking can be reported to info@sternberg-consulting.com. Reports are treated confidentially.
Reports may also be made anonymously where practically possible. People who raise concerns in good faith must not be disadvantaged for doing so.
Responsibility
Responsibility for this policy lies with Jonathan Sternberg. The policy is reviewed when relevant changes occur in business activities, supplier structure, or legal requirements.
Review
This policy is reviewed annually. Last reviewed: March 2026.