Modern Slavery and Human Trafficking Policy

Last Updated: March 19, 2024

This policy (the “Policy”) has been published and is made on behalf of Ltd. (the “Company,” “we” or “our”). 

As a global organization, the Company is committed to high standards of ethical conduct and compliance with applicable laws and, as such, has a zero-tolerance approach to modern slavery and human trafficking. We are further committed to implementing effective systems of controls to ensure modern slavery and human trafficking are not taking place within our own business or in any of our supply chains. It is our expectation that our suppliers and business partners also conduct themselves in this manner. 

This Policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners (each a “Covered Party”).


We expect each Covered Party to read, understand and comply with this Policy in order to assist in the prevention, detection and reporting of instances of modern  slavery and/or human trafficking, and should any Covered Party have knowledge or suspicion of instances of  modern slavery and/or human trafficking relating to or connected to the Company, then they should inform their manager, or the Company’s Legal team, as soon as possible.

The Company aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern.

Due diligence in the supply chain

The Company carries out risk assessments in relation to its suppliers. Where the Company identifies potential risks, we seek to increase our internal and external diligence protocols to ensure that all our suppliers are compliant with the code of conduct for our Vendors and all applicable national regulations.

Where we suspect that any of our suppliers are relying on or benefitting from modern slavery or human trafficking, we will make any necessary reports to the relevant authorities, and where such suspicion materializes or appears to be true – we will seek to terminate our relationship with that supplier.

Compliance with this Policy

All Covered Parties are expected to adhere to the requirements set out herein. In the event of any breach of this Policy, we will carefully consider the circumstances. In relation to our employees, any breaches of this Policy will be addressed through our disciplinary process and could ultimately result in dismissal. In respect of any other individuals or organisations with whom we have a business relationship, we will engage with such individuals or organisations and consider the appropriate steps to take. Such steps could involve a review of the risk mitigation measures in place, a requirement for the individual/organisation to remedy any identified breach, ongoing monitoring obligations, or the potential termination of the business relationship where appropriate. 

This Policy has been approved by the Board of Directors of the Company.

Date Approved: February 7, 2024

Empowering teams to accomplish more, together

14-day free trial | No credit card needed