1.1 Introduction
This Modern Slavery Statement is published by Ascendia Prime Media Ltd.
Ascendia Prime is committed to conducting business ethically, transparently and responsibly. We have zero tolerance for modern slavery, human trafficking, forced labour, child labour, debt bondage, servitude or exploitation in our business or supply chains.
Although Ascendia Prime may not currently be legally required to publish a modern slavery statement based on turnover thresholds, we consider it good practice to set out our position clearly.
1.2 Our Business
Ascendia Prime Media Ltd is a UK-based performance marketing and digital affiliate business. We provide services including affiliate marketing, campaign management, retargeting, remarketing, media partnerships, publisher activation and digital growth support.
Our business is primarily office-based and digital in nature.
1.3 Our Supply Chains
Our supply chains may include:
- Technology platforms.
- Tracking and analytics providers.
- Advertising technology suppliers.
- Cloud hosting and software providers.
- Freelancers, consultants and contractors.
- Media partners and publishers.
- Professional advisers.
- Office, operational and administrative suppliers.
While our direct business model is not generally considered high risk for modern slavery compared with sectors such as agriculture, manufacturing, logistics or construction, we recognise that risks can exist in global supply chains, outsourced services, offshore support, gig-based labour, content production, promotional services and digital supply chains.
1.4 Our Standards
We expect all suppliers, publishers, partners, contractors and service providers to:
- Comply with all applicable anti-slavery, human trafficking, employment and labour laws.
- Prohibit forced labour, child labour, bonded labour and human trafficking.
- Treat workers with dignity and respect.
- Provide lawful wages, working hours and working conditions.
- Avoid recruitment practices that exploit workers.
- Maintain safe and fair working environments.
- Notify us immediately of any actual or suspected modern slavery risk connected with our business.
1.5 Due Diligence
We may carry out proportionate due diligence on suppliers and partners, particularly where risk factors are identified.
This may include:
- Reviewing supplier reputation and business legitimacy.
- Checking contractual commitments.
- Assessing country, sector or labour-risk indicators.
- Requiring suppliers to confirm compliance with applicable laws.
- Investigating concerns or complaints.
- Terminating relationships where serious concerns are not resolved.
1.6 Affiliate and Publisher Network Controls
Ascendia Prime expects publishers, media partners, influencers, affiliates and advertising partners to operate responsibly and lawfully.
Partners must not use deceptive, exploitative or unlawful traffic generation methods. We may suspend or remove partners involved in fraud, hidden advertising, unlawful data use, misleading practices, unsafe content, exploitation or any conduct that may harm consumers, advertisers or Ascendia Prime.
1.7 Training and Awareness
We aim to promote awareness of ethical business conduct, responsible marketing, partner compliance and modern slavery risks within our team.
Relevant team members involved in supplier selection, publisher onboarding, campaign management or compliance should understand how to identify and escalate concerns.
1.8 Reporting Concerns
Concerns about modern slavery or unethical conduct connected to Ascendia Prime may be reported confidentially to:
Email: Marcio.fasano@ascendiaprime.co.uk
Subject line: Modern Slavery Concern
We will review concerns promptly and take appropriate action.
1.9 Actions for the Next 12 Months
Ascendia Prime aims to strengthen its modern slavery controls by:
- Including anti-slavery clauses in relevant supplier and partner agreements.
- Improving supplier and publisher onboarding checks.
- Maintaining a clear escalation process for concerns.
- Reviewing higher-risk supply chain areas as the business grows.
- Training relevant team members on responsible partner management.
1.10 Approval
This statement has been approved by the management of Ascendia Prime Media Ltd.
Signed:
Marcio Borlenghi Fasano
Director, Ascendia Prime Media Ltd
Date: 10 June 2026