Modern slavery can occur in various forms, including servitude, forced or compulsory labor, and human trafficking, all of which involve the deprivation of a person's liberty by another to exploit them for personal or commercial gain. This Statement's use of the term "modern slavery" has the meaning provided in the Act.
We are committed to conducting our business ethically and transparently, and do not tolerate any form of modern slavery within our supply chain. Our Code of Conduct provides a clear set of standards for our conduct as an organization and for all employees globally. Employees receive a copy of Afiniti's Code of Conduct at the start of their employment with the Company and are required to sign an annual declaration confirming they have understood and comply with its standards. Employees also receive periodic training to ensure the principles outlined in our Code of Conduct are an integral part of our culture. The Code of Conduct also outlines our expectations of our suppliers and vendors which are further enforced through our due diligence processes.
Due Diligence Processes
From time to time, Afiniti engages vendors and suppliers to purchase goods or services. We include anti-slavery clauses as part of our standard form contract for vendors and suppliers, requiring our vendors' and suppliers' commitment to preventing any form of slavery within their business or supply chain. As a practice, Afiniti also requests information from vendors and suppliers to confirm their compliance with the Act. While we cannot control the conduct of individuals or organizations in our supply chain, the following practical steps may be taken as necessary:
Our procurement team is trained to identify the signs of modern slavery and take action if it suspects that modern slavery is taking place in our supply chain. In accordance with our Code of Conduct, employees at all levels of the Company have a responsibility to report any known or suspected activity that could involve modern slavery. Afiniti employees are encouraged to familiarize themselves with our procedures to help in the identification and prevention of modern slavery and to conduct business in a manner that does not allow the occurrence of modern slavery.
Reporting Modern Slavery or Human Trafficking
We have a Reporting and Anti-Retaliation policy that provides guidance for all employees on how to raise concerns confidentially without fear of reprisal. Since September 2018, we have offered a whistle-blower hotline managed by an independent vendor to assist in employee reporting. Employees of Afiniti are expected to raise concerns at any time if they:
We promptly investigate any concern raised, as appropriate. If a concern involves an employee of a vendor or supplier, the vendor or supplier will be given time to investigate as necessary. If we make a reasonable conclusion that a violation has occurred there can be material consequences, which may include requiring the supplier to remediate the issue, disciplinary action up to termination of employment (for an employee of Afiniti), or termination of a contract (for a vendor or supplier).
This Statement has been approved by the Board of Directors of Afiniti Europe Technologies Ltd.
CEO, Afiniti, Ltd.