Anti-Slavery and Human Trafficking Policy

The Directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Directors and line managers will remain alert to indicators of modern slavery and will respond appropriately if they find or are informed of any indication of modern slavery.

This policy statement is reviewed annually by the Information Security team to ensure:

• The business meets its compliance obligations
• It maintains its relevance to the business’ current and planned sensitive data processing operations.

The Information Security team on behalf of the Directors / Head of Information Security will undertake the technical review of this policy statement and associated company policies.

This policy is made pursuant to Section 54(1) of the Modern Slavery Act 2015.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

We have a zero-tolerance approach to modern slavery and we are committed to acting ethically, transparently and with integrity in all of our business dealings and relationships. We will implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

This policy applies equally to our third party supply chain, including hardware manufacturers and suppliers, software providers, recruitment and employment agencies from whom BONAFiDEE employees may be sourced, and to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, workers, agency workers, interns, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

The principal areas in which BONAFiDEE faces risks related to modern slavery include:

• the BONAFiDEE Supply Chain and outsourced activities and in particular those Suppliers located in overseas jurisdictions identified through the Global Slavery Index as higher risk, in accordance to the scoring criteria defined by the Global Slavery Index (https://www.globalslaveryindex.org/2018/data/maps/#prevalence).
• recruitment in our own business, particularly recruitment through agencies; and
• any Supplier that is identified as working in a higher risk area such as manufacturing or cleaning.

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a slavery or trafficking victim.

This list is not exhaustive:

• the person is not in possession of their own passport, identification, travel documents or bank account;
• the person is acting as though they are being instructed or coached by someone else;
• they allow others to speak for them when spoken to directly;
• they are dropped off and collected from work;
• the person is withdrawn or they appear frightened;
• the person does not seem to be able to contact friends or family freely; and
• the person has limited social interaction or contact with people outside their immediate environment.

If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify infosec@bonafidee.com as soon as possible.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any part of our business or tier of the BONAFiDEE Supply Chain constitutes any of the various forms of modern slavery, you should raise it with infosec@bonafidee.com.

We aim 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 the BONAFiDEE Supply Chain. All notifications received, together with the identity of the notifier, will be treated in the strictest confidence.

We are a provider of software as a service solution. Our company is based in Tunbridge Wells and our solutions are operated out of data centres within the UK.

Annual Anti-Slavery Statement: under Section 54 of the Modern Slavery Act, commercial organisations that carry on a business in the UK, supply goods and services and have a total annual turnover of £36 million or more, are required to publish within six months of the end of each financial year, an annual statement. This must set out the steps (if any) that the organisation has taken during the financial year to ensure that modern slavery is not taking place in any of its supply chains and in any part of its own business. The statement must be signed by a Director and published on its website with a clear link on the homepage.

This does not currently apply to BONAFiDEE Ltd.

Supply Chains: we take one or more of the following actions in respect to each Supplier:

• our standard supply chain prequalification questionnaires contain anti-slavery provisions which prohibit Suppliers and their employees and sub-suppliers from engaging in modern slavery;
• in cases of high-risk, we audit the Supplier and, as appropriate, we require them to take specific measures to ensure that the risk of modern slavery is significantly reduced and reserve the “right to audit” our Suppliers; and
• if modern slavery is actually identified in our business or in the BONAFiDEE Supply Chain, we require that immediate action is taken to address it, and we provide appropriate support to this end. In the event of failure to resolve the situation with a Supplier rapidly

Recruitment: we take the following actions:

• we always ensure all staff have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work;
• we always ensure staff are legally able to work in the country in which they are recruited;
• we provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to;
• if, through our recruitment process, we suspect someone is being exploited, our reporting procedures are followed; and
• we conduct due diligence checks on any recruitment agency that we use to ensure that it is reputable and conducts appropriate checks on all staff that they supply to us.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with Suppliers and other third parties if they breach this policy.

In addition, procurement includes various services to support the business including:

• secure colocation facilities
• professional services
• project management services
• public network telephony, networking and data services;
• logistics services (for example, couriers and warehousing); and
• facilities services to provide corporate support to the company

We have also taken the step of reviewing the existing training carried out within the business to ensure that its supply chain operates in an ethical and compliant manner. Training on the prevention of modern slavery shall be delivered to critical departments, such as Procurement and Information Security.

Information Security cascade the awareness of this policy and procedure to all employees on an annual basis.

The company acknowledges that the controls put in place to manage the risk posed from modern slavery require regular review. As such, we will continue to evaluate the effectiveness of these measures to ensure that the risk of modern slavery in the company supply chain is mitigated.  We will provide information and/or training on any changes made as a result.

This policy is approved by the Board and approved for release and is reviewed at least annually. Training and information is provided on any changes made as a result.

This policy will be made available to all employees.