Policy Statement

The Board and management of Eviid, the head office of which is located in D prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

The policy is subject to continuous, systematic review and improvement.

Scope

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers. Any agreements with clients will contain language similar that protects the fund.

Definitions

Modern Slavery and Human Trafficking – Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Policy Commitment

• We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
• The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
• We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
• We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to  combat modern slavery and trafficking.
• Consistent with our risk-based approach we may require:
  • employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct
  • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code
• As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
• If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

Slavery Compliance Officer

The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.

Policy Compliance

If any user is found to have breached this policy, they may be subject to Eviid’s disciplinary procedure as laid out in the company Staff Handbook. If a criminal offence is considered to have been committed further action may be taken to assist in the prosecution of the offender(s). If you do not understand the implications of this policy or how it may apply to you, seek advice from HR Department or the Slavery Compliance Officer.

Policy Governance

The following table identifies who within Eviid is Accountable, Responsible, Informed or Consulted with regards to this policy. The following definitions apply:

Responsible – the person(s) responsible for developing and implementing the policy.
Accountable – the person who has ultimate accountability and authority for the policy.
Consulted – the person(s) or groups to be consulted prior to final policy implementation or amendment.
Informed – the person(s) or groups to be informed after policy implementation or amendment.

Review and Revision

This policy will be reviewed as it is deemed appropriate, but no less frequently than every 12 months.
Policy review will be undertaken by the Slavery Compliance Officer.