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 firstname.lastname@example.org, 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.