Anti-Slavery & Human Trafficking Policy

Date: 27 January 2021

Version: 1

Document Status: Published Classification: Public

Anti-Slavery & Human Trafficking Policy

Bravura Solutions Limited and its subsidiaries (the Company)

1.Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced 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 and with integrity in all our business dealings and relationships. We expect th e same high standards from all our contractors, suppliers and other business partners.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, direct ors, officers, agency workers, seconded workers, volunteers, agents, contractors, consultants and business partners. This policy does not form part of any employee's contract of employment and we may amend it at any time.

Please refer to our Modern Slavery Act Statement in the Corporate Governance section of our website, located athttps://bravurasolutions.com,which sets out how we assess potential modern slavery risks and what steps we put in place to ensure that there is no slavery or human trafficking in our business or supply chains. This statement is reviewed and updated annually with approval from the board of directors.

2.Responsibility for the policy

The board of directors has overall responsibility for ensuring this policy complies with our legal obligations. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

3.Compliance with the policy

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 must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or m ay occur in the future. 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.

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or report it in accordance with our Whistleblowing Policy 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 tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the compliance officer.

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 in our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising your concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

4.Communication and awareness of this policy

All employees will be made aware of this policy and it will form part of the induction of all new starters. Our zero -tolerance approach to modern slavery must also be communicated to all supplier, contractors and business partners by the relevant stakeholders.

5.Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could resul t in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Signed

Tony Klim

Chief Executive Officer Date 27 January 2021

Attachments

  • Original Link
  • Original Document
  • Permalink

Disclaimer

Bravura Solutions Limited published this content on 28 March 2022 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 22 April 2022 01:37:08 UTC.