Modern Slavery and Human Trafficking Policy

Purpose and Scope

PURPOSE - To prevent modern slavery in our organisation and supply chains, by increasing transparency by ensuring the public, consumers, employees and investors know what steps our organisation is taking to tackle modern slavery.

SCOPE - This Policy applies to all employees including temporary, migrant, student, contract, direct employees and any other type of employee within the business. Due diligence processes are established to address the risk of slavery and human trafficking taking place within our business and supply chain.

Policy

Hicomply Limited’s business is the provision and support of a SaaS application. We are committed to upholding the human rights of all employees, treating them with dignity and respect and complying with all applicable laws and regulations. This includes the prevention of human trafficking and slavery.

Operation

Modern Slavery Act

Section 54 of the Modern Slavery Act 2015 requires organisations with significant turnover to develop a slavery and human trafficking statement.

Hicomply Ltd’s slavery and human trafficking statement highlights what steps we take to ensure modern slavery is not taking place in our business or supply chains.

Commitment

• We train all employees to implement our policies and ensure we meet applicable legal requirements, including the prevention of human trafficking and slavery. Employees are able to recognise and respond to any instances of modern slavery, during work time or otherwise.

• We carry out internal reviews of suppliers and by taking a risk assessment approach we can identify and understand the potential risks and so ensure we can respond appropriately to any challenges.

• Reviews of all contracts and terms of business are completed and include provisions to ensure we have the right to terminate any supplier contract where modern slavery legislation has not been adhered to.

• Hicomply will not knowingly use child labour or forced labour in any of our services or accept services from suppliers that are not taking similar steps to combat such unlawful practices.

Incident Management

Modern slavery and human trafficking are serious offences. If a specific case of modern slavery is identified, during working hours or otherwise, it will be reported to the police immediately on 101. If potential victims are in immediate danger the standard 999 emergency will be used.

In the UK, mechanisms are in place to assist victims of slavery and human trafficking. A potential victim can be referred to the National Referral Mechanism to be formally identified as a victim of modern slavery and offered Government support. Referral for potential adult victims is by consent.

The Modern Slavery Helpline on 0800 0121 700 will allow anyone who thinks they may have come across an instance of modern slavery, or indeed who may be a victim themselves, to call for more information and guidance.

Enforcement and Violations

ENFORCEMENT - All divisions & employees of the organisation must comply with the requirements of this policy. Management are responsible for ensuring that the policy is implemented within its area of responsibility.

Hicomply Limited expects all users to comply with the terms of this policy and all other policies, procedures, guidelines and standards published in its support.

VIOLATIONS - Violations of this policy shall result in disciplinary action / legal ramifications by the organisation. Disciplinary action will be consistent with the severity of the incident as determined by an investigation and as deemed appropriate by Management and HR.

Compliance with this policy will be reviewed by the organisation’s IMS Committee.

Edwin Bartlett
CEO

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