Avast plc, together with its subsidiaries, including Avast Software s.r.o., AVG Technologies Limited, Piriform Software Limited (‘CCleaner’), Privax Limited (‘HideMyAss!’), and any contractors, representatives and agents while they are working on our behalf (together ‘Avast’).
These Guidelines spell out the social, ethical and environmental standards and expectations for our supply chain. In line with global regulations, our core values, Avast Modern Slavery Policy, Code of Conduct and other related policies, these Guidelines encapsulate the principles we abide by and uphold. In your association with us as our partner, supplier, contractor or otherwise, we expect these values and standards to be upheld, along with the laws, rules and regulations of the countries from which you operate. Abiding by the Guidelines also means that you take responsibility for whoever you subcontract to perform your agreement with us as they too form a part of our supply chain. Any evidence of a breach of our Supplier Guidelines may result in the termination of our contractual relationship.
Our Guidelines are based on international standards, modelling and using some of the language from several sources, including the United Nations Guiding Principles on Business and Human Rights (UNGP), the Ethical Trading Initiative Base Code (ETI), the Responsible Business Alliance Code of Conduct (RBA), Managing Risks Associated with Modern Slavery A Good Practice Note for the Private Sector (GPN), the Universal Declaration of Human Rights (UDHR), International Labour Organisation Declaration on Fundamental Principles and Rights at Work (ILO Declaration), and the Australian Government Department of Home Affairs Modern Slavery Act 2018 Draft Guidance for Reporting Entities.
We uphold the human rights of workers and treat every worker with dignity and respect in accordance with international standards. By ‘worker’, we include those that are permanent, temporary, contract and student.
We do not discriminate against any worker on the basis of the worker’s race, color, age, gender, religion, ethnicity, disability, sexual orientation, political affiliation, union membership, national origin, or marital status in our hiring and employment practices such as training, promotions, rewards, job assignments, wages, benefits, discipline, termination, and retirement. We may not ask for a pregnancy test or discriminate against pregnant workers, except where it is required by relevant laws or regulations. We also do not ask workers or potential workers to undergo medical tests or physical exams that may be used to discriminate, except where required by applicable law or regulation or necessary for workplace safety.
No Involuntary Labour
We do not force or threaten our workers to do their jobs. We may not use any form of forced, bonded, indentured, or exploitative prison labour. We may not ask our workers to surrender any government-issued identification, passports, or work permits, unless required by law. Our workers have freedom of movement to come and go, and to terminate their employment with reasonable notice.
No Child Labour
We do not employ children. The minimum age for employment or work shall be 15 years of age, the minimum age for employment in the relevant country, or the age for completing compulsory education in that country, whichever is greater.
Student, Intern and Apprentice Labour
We provide appropriate support and training to our student, intern and apprentice labour, and ensure they are adequately paid according to the standards set by local law or if not set, at least the same wage rate as other entry-level workers performing equal or similar tasks.
- Working Conditions
We value our workers and believe a healthy happy workforce is more productive. Studies have shown that long hours do not necessarily result in higher productivity, and in fact, the reverse may occur.
Unless there is an exceptional situation, working hours should not go beyond 60 hours, including overtime. Our workers must be allowed at the minimum one day off a week, and working hours are not to exceed the maximum hours set under the applicable laws and regulations of that country. We must offer our workers vacation time, leave periods, and holidays consistent with relevant laws and regulations.
Wages and Benefits
We are required to pay our workers at least the minimum wage and all compulsory benefits required by relevant laws and regulations. Overtime shall be paid at a higher rate than the regular hourly rate in accordance with relevant laws and regulations. We do not use deductions from wages as a disciplinary measure. We pay our workers in a timely and regular manner, providing them with a wage statement that is comprehensible to them.
Freedom of Association
We respect our workers’ right to associate freely, freely form and join workers’ organizations, seek representation, and bargain collectively, in line with relevant laws and regulations.
No Harsh Treatment and Harassment
We must not harass our workers, nor threaten them or deal with them in a harsh or inhumane manner. This means there must be no sexual or verbal harassment or abuse, corporal punishment, mental or physical coercion of the workers.
- Occupational Health and Safety
We commit to creating a safe and healthy work environment for all workers. We maintain safe and healthy workplaces by having proper health and safety management practices integrated into all aspects of the business.
Occupational Safety and Industrial Hygiene
We assess worker potential to exposure of safety hazards in our workplaces, including exposure to any hazardous chemical, biological and physical agents, providing appropriate controls, safe work processes, preventative maintenance, and protective measures to control health and safety risks.
Whatever the safety risk, measures must be taken, including providing workers with appropriate personal protective equipment. Workers must be able to refuse unsafe working conditions without fear of reprisal, and management must address their concerns to render the situation safe.
We take care of the health and safety of our workers by making sure we foresee, identify and assess potential emergency situations in order to mitigate such risks. We put in place appropriate emergency plans and response procedures including evacuation procedures, handy first-aid supplies, fire drills, and adequate exits.
Occupational Injury and Illness
We must have a proper system in place to manage, track, and report occupational injury and illness so that we can investigate the occurrences and implement remedial actions to rectify or eliminate the causes, ensure the proper medical treatment, and put in place a return to work policy for those who were impacted.
Physically Demanding or Repetitive Work
We must identify, assess, and manage worker exposure to physically demanding and mentally taxing tasks, including heavy lifting, prolonged standing, or highly repetitive tasks.
We provide our workers with clean toilet facilities, access to safe drinking water, and where there is a canteen, sanitary food preparation and storage. Where workers live in company provided living quarters, these places must be clean and safe, reasonably spacious with appropriate fire alarms and exits, sufficient heating and ventilation.
We must provide our workers with relevant workplace health and safety information for all the occupational hazards the workers are exposed to, as well as proper training to manage the risks.
- Business Conduct and Ethics
We uphold the highest ethical standards in business dealings to meet our social responsibilities.
We do not tolerate corruption, bribery, extortion, and embezzlement. We make sure we comply with all applicable laws and international conventions regarding these matters, including the United Nations (UN) and Economic Co-operation and Development (OECD) conventions.
No Conflict of Interest
We must not have any conflict of interest in our business decisions, therefore we ask our partners and potential partners not to send invitations and gifts to gain any form of influence. Any gifts or invitations to our employees must be of low financial value and in accordance with ordinary local business custom or courtesy.
Our business dealings should be transparent and reflected in our company books and records. In line with applicable laws and best practices, we disclose all required information. It is unacceptable to falsify records or misrepresent conditions or practices.
We respect intellectual property rights, and ensure that the transfer of technology and knowledge is done in a manner that protects intellectual property rights, as well as customer and supplier information.
We commit to protecting the personal information of those we do business with, and adhere to privacy and information security laws and regulatory requirements where personal information is collected, stored, processed, transmitted, and shared.
We uphold standards of fair business, advertising and competition.
We are committed to considering the environment in what we do, and to create sustainable workplaces.
We aim to reduce harmful environmental impacts through our designs, processes, and recycling of waste. We look for cost-effective ways to be energy efficient and to reduce greenhouse gas emissions. Our supply chain must comply with all applicable laws and regulations prohibiting or restricting specific substances, emissions, and pollution.
We must identify and manage substances that are environmental risks. We are guided by the relevant laws regarding any hazardous or toxic substances used in the workplace and appropriately train workers who are exposed to them.
Permits and Registrations
We apply all required environmental permits and registrations. We expect our supply chain to develop an Environmental Management System that complies with ISO 14001 or similar.
- Conflict Minerals
We do not support or finance directly or indirectly armed groups that perpetuate serious human rights abuse in the Democratic Republic of Congo or an adjoining country.
Responsible Sourcing of Minerals
As part of our global responsibilities, we expect our suppliers to comply with all applicable conflict minerals regulations and to source responsibly. If the product supplied contains one or more of the ‘conflict minerals’ (tin, tantalum, tungsten and gold or their ores), the partner or supplier shall provide, on request, transparency on the supply chain up to the smelter. Therefore, we should maintain a complete set of records to trace the provision of all goods and services to us.
- Management Systems
We commit to putting in place management systems that help us to identify and mitigate operational risks, comply with relevant laws and regulations relating to operations and products and keep us in conformity with these Guidelines.
We identify the senior executives and representatives responsible for implementing the compliance management systems. Senior management regularly reviews the management systems.
We regularly identify, keep abreast of and understand the applicable laws and regulations, including the requirements of these Guidelines, in order to determine operational risks and ensure compliance.
Modern Slavery Due Diligence
We must exercise due diligence in checking that our supply chain and its officers, employees or other persons associated with it have not been convicted of any offence involving slavery and human trafficking.
By making reasonable enquiries, we must ensure any potential partner, supplier, contractor or otherwise, to the best of its knowledge, is not the subject of any investigation, inquiry or enforcement proceedings by any governmental, administrative or regulatory body regarding any offence or alleged offence of or in connection with slavery and human trafficking.
We must put in place due diligence procedures to monitor suppliers, subcontractors and other participants to ensure the absence of slavery or human trafficking.
Modern Slavery Reporting
Our partner must notify us as soon as it becomes aware of any actual or suspected slavery or human trafficking in their supply chain which has a connection with us.
Upon request, our supply chain partner shall prepare and deliver to us no later than five months after the end of each year, that is by 31 May, an annual slavery and human trafficking statement setting out the steps it has taken to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its business.
Whistleblowing and No Retaliation
We have in place a grievance reporting mechanism, such as a Hotline, and ensure our employees and subcontractors are aware of their rights in relation to reporting.
We have a Whistleblower Policy, including a No-Retaliation clause for the protection of those who use it, and to record and handle complaints identifying occupational risks to health or safety or incidences of modern slavery and human trafficking.
Where our supply chain cannot reasonably establish a reporting mechanism, supply chain employees and subcontractors should be made aware that our Whistleblower Hotline is available 24 hours per day, 7 days per week, and can be contacted worldwide by dialing the local number (which should be made available to all staff and subcontractors) or by email to email@example.com, or online via the Avast Ethics & Reporting Line.
Auditing and Monitoring
We may audit our supply chain as part of our due diligence process. This may include announced or unannounced on-site visits to Company’s facilities by our employees or agents, including but not limited to third-party auditors, to monitor and verify compliance with these Guidelines.
We may ask for access to information relevant to monitoring modern slavery, human trafficking and other risks, including but not limited to: employment contracts, recruitment agency contracts, records of wages, time worked, and confirmation of payment.
Where we reasonably suspect that modern slavery or human trafficking or other breaches are or may be occurring within our business or supply chain, we reserve the right to investigate such concerns and our supply chain partner warrants to provide full cooperation to ensure investigations can be completed. If necessary, we may work with the supply chain partner to implement corrective action plans in collaboration with top-level management to address and resolve any identified issues.
We ensure training for relevant employees so they understand the principles of the Modern Slavery laws, social, ethical and environmental laws, be able to spot red flags, and prevent incidents of modern slavery, human trafficking and other issues. We expect our supply chain to keep a record of all training offered and completed by its employees and to make a copy of the record available upon request.
We commit to working with our supply chain to implement corrective action plans to remedy incidents or risks of modern slavery, human trafficking, and other issues, where possible. Any single serious or persistent breaches of the applicable laws, statutes and regulations in force may result in termination of the contractual relationship and/or reporting to the relevant authorities.