Modern Slavery and Human Trafficking Policy
Version: 3.0. Last update: January 2024
This statement sets out Eigen Technologies actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.
As part of the technology sector, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
Eigen Technologies is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Eigen Technologies have a diverse supply base, who supply both services and products to our work locations within the UK, Lisbon and New York. We have undertaken to write to these suppliers highlighting the act to them and reaffirming our commitment to ensuring that slavery and human trafficking are not taking place within the supply base.
We have inserted a section about the Modern Slavery Act within our standard terms and conditions. These T&Cs are issued to all our suppliers along with all Purchase Orders further highlighting the need for suppliers to ensure that their staff and supply chain are aware of the Act, how it applies to them and their responsibilities to Eigen Technologies as an approved supplier.
During applicable contract start up meetings with our suppliers we request that suppliers show evidence to demonstrate that both they and their sub suppliers have taken steps to ensure they are compliant with the Modern Slavery Act (as it applies and or ethically in line with this policy).
Eigen Technologies operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
• Whistleblowing: The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
• Employee code of conduct: The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:
• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
• evaluating the modern slavery and human trafficking risks of each new contract
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• conducting supplier audits or assessments, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• creating an annual risk profile for each supplier;
• taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to implement action plans;
• participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking
• invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship
All permanent current employees will be taken through a presentation explaining our commitment to the Modern Slavery Act. All new permanent employees will also be taken through the presentation or video as part of the induction into the company.
This document is valid as of 31 January 2023. The owner of this document is the People Director, who must check and, if necessary, update the document at least once a year.
If you have any questions in relation to this, please email [email protected].
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