Facepunch Studios Limited is a 100% wholly owned subsidiary of Facepunch Group Limited (together referred to as Facepunch). Here at Facepunch, we are committed to observing our legal and ethical obligations towards combating modern slavery and human trafficking, and to monitoring and improving our practices in this area on an ongoing basis, pursuant to section 54 of the Modern Slavery Act 2015.  

This statement covers the financial year ending 30th September 2022 and sets out the steps that Facepunch continues to take to prevent modern slavery and human trafficking in its business and supply chains.

Organisation structure and business

Facepunch was founded by Garry Newman in March 2009. It is a game development company developing games mainly in the United Kingdom for sale worldwide. The games currently being developed are principally downloadable and multiplayer/openworld.

Our supply chain 

We procure a range of goods and services through our supply chain which includes contractors, computer equipment, computer software, utility providers and professional services connected with game development (collectively referred to as ‘suppliers’ in this statement). 

Considering the potential consequences that a decision may have on our suppliers, as well as our employees, customers, and other related parties is paramount. Acting with honesty,  integrity, fairness and promoting high standards across the business is fundamental to how we operate as a business. And as such, Facepunch expects all suppliers to demonstrate a zero tolerance approach to any exploitation. We take a risk-based approach to our supplier processes which are then kept under review. 

The company is aware of its responsibility to the local community and the environment, making charitable donations and contributing to the local community on a number of different initiatives. Ultimately, we aim to increase the value of the business through building lasting relationships with our external partners and creating opportunities for employees and stakeholders to achieve their potential. 

Our policies on modern slavery and human trafficking

We regularly review and amend our company policies, to ensure that we are conducting business in an ethical and transparent manner. We communicate this via our Staff Handbook and this includes the following:

• Recruitment policy 

• Equal opportunities policy 

• Whistle blowing policy 

• Anti-Bribery, Corruption and Fraud policy 

• Anti Slavery & Human Trafficking policy 

Due diligence and risk assessment

Our overall objective is to establish and maintain relationships with our suppliers that minimises the risk that slavery or human trafficking could occur within our supply chains. 

To mitigate against the risk of modern slavery and human trafficking in our supply chains, risk assessment and due diligence focuses on our supplier relationships. When contracting with new suppliers we take a risk-based approach to our contracting processes, with emphasis on the larger contractors but ensuring this is done on a contractor by contractor basis. As at the date of this statement there have been no instances that have presented themselves where modern slavery and human trafficking have been identified.

Training

Training is sourced and provided to relevant staff from time to time to ensure that Facepunch and our team are aware of the signs and impact of modern slavery and human trafficking and that due diligence is being undertaken on suppliers. 

Our effectiveness in combating slavery and human trafficking

Given our usually stable supply chain, which comprises suppliers that share our values, our business is self-assessed as low risk in respect of modern slavery and human trafficking in both our own business and in our immediate supply chain.

We have a zero tolerance approach to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we operate in line with principles of responsible sourcing, including paying employees at the prevailing minimum wage.