Modern Slavery Act Policy

Modern Slavery Act Policy

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.

At Includability we have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships. Imperative to this is implementing and enforcing 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 is designed to comply with, and support compliance with the Modern Slavery Act 2015.

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure include due diligence of the supplier's reputation, respect for the law, and compliance with health, safety and environmental standards.

We haven't been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.

Includability operates the following policies for identifying and preventing slavery and human trafficking in our operations:

• Whistleblowing Policy- we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation.
• Includability Written Code of Ethics- our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when throughout our operations and management of our supply chain.

We require our suppliers to attest that:

• They don't use any form of forced, compulsory or slave labour.
• Their employees work voluntarily and are entitled to leave work.
• They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment.
• They don't require employees to post a deposit/bond and don't withhold their salaries for any reasons.
• They don't require employees to surrender their passports or work permits as a condition of employment.