Modern Slavery Statement

Last updated: 5/20/2023 - mm/dd/yyyy

Introduction

1.1. At Teamflect, we are dedicated to conducting our business ethically and responsibly. We are committed to preventing modern slavery, human trafficking, and forced labor in all its forms. This policy sets out our approach to addressing and eradicating these practices within our organization and supply chains.

1.2. Modern slavery encompasses various forms of exploitation, including forced labor, debt bondage, human trafficking, and child labor. We believe that everyone has the right to work in a safe and inclusive environment, free from any form of coercion, exploitation, or abuse.

Policy Statement

2.1. Teamflect condemns all forms of modern slavery and is committed to acting ethically and with integrity in all our business operations. We strive to ensure that slavery and human trafficking have no place in our business or supply chains. To achieve this, we will:

• 2.1.1. Uphold our responsibilities under the Modern Slavery Act 2015 and any other relevant legislation or regulations relating to modern slavery and human trafficking. This includes ensuring compliance with reporting obligations, conducting due diligence, and taking appropriate action in response to any identified instances of modern slavery.
• 2.1.2. Prevent modern slavery by implementing robust policies, procedures, and controls across our organization. These measures will be regularly reviewed and updated to ensure their effectiveness in preventing, detecting, and responding to modern slavery risks.
• 2.1.3. Raise awareness among our employees and stakeholders about the risks, indicators, and consequences of modern slavery. Through training and education, we will equip them with the knowledge to identify and report any suspicions or concerns related to modern slavery promptly.
• 2.1.4. Conduct due diligence to identify and assess potential risks of modern slavery within our operations and supply chains. We will implement appropriate measures to mitigate these risks and promote responsible practices among our suppliers, contractors, and business partners.
• 2.1.5. Work collaboratively with our suppliers, contractors, and business partners to promote responsible and ethical practices. We will engage them in dialogue to understand their practices and encourage their compliance with anti-slavery standards. We will also support their efforts to eradicate modern slavery within their own operations and supply chains.
• 2.1.6. Investigate and take appropriate action against any reported instances of modern slavery within our organization or supply chains. This may involve working with law enforcement agencies and cooperating fully with any investigations.

Risk Assessment and Due Diligence

3.1. We recognize the importance of conducting comprehensive risk assessments and due diligence to identify and mitigate the risk of modern slavery. To ensure a proactive approach, we will:

• 3.1.1. Conduct regular assessments to identify areas of potential exposure to modern slavery, considering factors such as industry, geographic location, and vulnerable groups. This will enable us to focus our efforts on high-risk areas and take appropriate measures to address potential vulnerabilities.
• 3.1.2. Evaluate and monitor our supply chains, including suppliers, contractors, and business partners, to ensure compliance with anti-slavery standards. This includes conducting pre-screening, audits, and assessments of their practices to assess their commitment to eradicating modern slavery.
• 3.1.3. Implement measures to verify and assess suppliers' adherence to our standards. We will work collaboratively with them to address any identified areas of improvement and promote responsible practices. Where necessary, we will provide support and resources to assist our suppliers in implementing effective modern slavery prevention measures.
• 3.1.4. Encourage our suppliers, contractors, and business partners to provide transparency regarding their own efforts to combat modern slavery. We will evaluate their progress and take appropriate action if non-compliance is identified, including termination of the business relationship if necessary.

Training and Awareness

4.1. We are committed to promoting awareness and understanding of modern slavery among our employees, suppliers, and stakeholders. To achieve this, we will:

• 4.1.1. Provide comprehensive training to our employees, ensuring they understand the risks, indicators, and reporting mechanisms related to modern slavery. We will equip them with the necessary knowledge and skills to identify and report any suspicions or concerns promptly.
• 4.1.2. Raise awareness among our suppliers, contractors, and business partners by communicating our expectations regarding ethical practices and compliance with anti-slavery standards. We will encourage their employees to undergo relevant training and engage in responsible business practices.
• 4.1.3. Foster a culture of openness and transparency, where employees and stakeholders feel comfortable reporting any suspicions or concerns related to modern slavery. We will provide a confidential and accessible reporting mechanism and ensure that such reports are treated with confidentiality and that appropriate action is taken promptly.
• 4.1.4. Regularly communicate updates, best practices, and case studies related to modern slavery to maintain a high level of awareness and engagement across our organization and supply chains. We will leverage various communication channels to reach our stakeholders effectively.

Communication and Disclosure

5.1. We are dedicated to transparency and open communication regarding our efforts to combat modern slavery. To achieve this, we will:

• 5.1.1. Publish a Modern Slavery Statement, in accordance with legal requirements, outlining the steps we have taken to prevent modern slavery and the progress made. This statement will be publicly available on our website and will provide relevant information to our stakeholders.
• 5.1.2. Communicate our Modern Slavery Policy to our employees, suppliers, and stakeholders, making it easily accessible on our website or intranet. We will also provide regular updates to ensure awareness and understanding of our commitment to eradicating modern slavery.
• 5.1.3. Collaborate with industry partners, non-governmental organizations, and relevant authorities to share best practices, knowledge, and experiences related to combating modern slavery. We will actively engage in initiatives and forums that promote responsible business practices and the eradication of modern slavery.

Compliance and Monitoring

6.1. We are committed to continuous improvement and compliance with this policy. To ensure ongoing effectiveness, we will:

• 6.1.1. Regularly review and update our policies, procedures, and controls to ensure they remain aligned with best practices and evolving legal requirements related to modern slavery. We will engage internal and external stakeholders, including legal professionals, to ensure compliance and effectiveness.
• 6.1.2. Monitor and evaluate our performance in addressing modern slavery risks and take appropriate action to address any identified gaps or areas for improvement. This includes conducting internal and external audits, as deemed necessary, to assess compliance with this policy and applicable legislation.
• 6.1.3. Collaborate with relevant authorities and organizations to share knowledge, experiences, and best practices related to combating modern slavery. We will actively contribute to industry-wide efforts to eradicate modern slavery and promote responsible supply chain practices.
• 6.1.4. Conduct periodic reviews of our supplier and contractor relationships to ensure ongoing compliance with our standards. This may include verifying the effectiveness of their modern slavery prevention measures through audits, assessments, and engagement.

Responsibility and Accountability

7.1. Overall responsibility for the implementation and effectiveness of this policy rests with the senior management team at Teamflect. They will ensure that appropriate resources and support are provided to uphold the commitments outlined in this policy.

7.2. Every employee, supplier, and stakeholder has a responsibility to adhere to this policy and report any concerns related to modern slavery promptly. Compliance with this policy forms part of our contractual agreements with suppliers, contractors, and business partners. We will take appropriate action in response to any breach of this policy, including termination of business relationships if necessary.

Actions Taken by Teamflect as a Software Business

8.1. As a software business, Teamflect has implemented targeted measures to address the issue of modern slavery. We understand the unique dynamics of our industry and have taken the following actions:

• 8.1.1. Supplier Evaluation: We conduct thorough evaluations of our software development partners, cloud service providers, and other suppliers to ensure they uphold ethical standards and demonstrate a commitment to eradicating modern slavery. We prioritize working with suppliers who share our values and actively engage in responsible business practices.
• 8.1.2. Internal Training and Awareness: Our employees, including software developers, managers, and other staff, receive training to raise awareness about modern slavery, its indicators, and reporting mechanisms. This empowers our workforce to identify and report any suspicions or concerns promptly, fostering a culture of vigilance against modern slavery.
• 8.1.3. Responsible Sourcing: We actively seek out suppliers who adhere to ethical sourcing practices and respect human rights. Through responsible sourcing strategies, we ensure that our supply chain is free from modern slavery and forced labor. We engage in dialogue with suppliers, encouraging them to adopt similar responsible practices within their own operations.
• 8.1.4. Compliance Monitoring: We have established mechanisms to monitor and assess supplier compliance with our anti-slavery standards. This includes conducting periodic audits and assessments to ensure ongoing adherence to ethical practices and to identify any potential risks of modern slavery within our supply chain.
• 8.1.5. Collaboration with Industry Peers: We actively collaborate with industry peers, participating in forums and initiatives aimed at combatting modern slavery in the software sector. Through these collaborations, we share best practices, exchange knowledge, and work together to drive industry-wide change and promote responsible business conduct.