Anti-slavery and human trafficking Policy

Flipnode LLC anti-slavery and human trafficking policy

Introduction

1. Modern slavery is a fundamental violation of basic human rights and a crime. It takes various forms including slavery, servitude, forced or compulsory labour and human trafficking. These offences are closely related but legally distinct:
   1. slavery is where ownership is exercised over a person;
   2. servitude involves the obligation to provide services imposed by coercion;
   3. forced or compulsory labour involves work or service exacted from any person under the menace of a penalty and for which the person has not offered himself or herself voluntarily; and
   4. human trafficking involves arranging or facilitating the travel of another with a view to exploiting them.
2. In all cases, some of the most vulnerable people in society are stripped of their dignity and basic freedoms, and forced to work for someone else’s gain or benefit. The most common forms of modern slavery are sexual exploitation, labour exploitation including child labour and domestic servitude.

Purpose of the Policy

3. This Policy expresses Flipnode’s commitment to the fight against modern slavery. It sets out our overall approach to that fight.

Policy statement

4. Flipnode is committed to taking all reasonable steps to ensure that modern slavery is not taking place:
   1. in any part of its own business; and
   2. in its supply chains.
5. Flipnode expects its leadership team and all members of staff to work with Flipnode to maintain these standards and to conduct their own personal and domestic affairs in such a way to ensure that they are in no way connected with modern slavery either through the commission of a criminal offence or through actions or omissions that might bring themselves and Flipnode into disrepute.
6. For the purposes of this Policy, “members of staff” means all persons working for or with Flipnode in any capacity including: employees, workers, contractors, secondees, interns, agents, consultants and agency workers.
7. Flipnode expects the same standards from all of its contractors, suppliers and other business partners. Flipnode will seek to ensure, where reasonably practicable, that its contractors, suppliers and other business partners are contractually obliged to comply with terms that reflect the spirit and intention of this Policy in their own businesses and in their own supply chains in support of the general eradication of modern slavery.
8. Flipnode will from time to time assess and review the risk that modern slavery may be occurring in any part of its own business and in any of its supply chains. In light of any such risk assessments it may from time to time seek specific reassurances from its contractors, suppliers and other business partners; and seek to carry out due diligence or specific audits either itself or through third parties to satisfy itself that modern slavery is not occurring.
9. Flipnode is committed to transparency in its approach to tackling modern slavery.

Application of the Policy

10. In the event that Flipnode has a reasonable belief that modern slavery is occurring in any part of its business:
    1. Flipnode will:
       1. put in place remedial action as soon as reasonably practical with a view to ensuring that such modern slavery ceases to occur and that the victims of that modern slavery are appropriately safeguarded; and
       2. monitor the effectiveness of the remedial action taken including the actions taken to safeguard the victims;
    2. Flipnode may, depending on the facts, deal with the matter under its disciplinary procedures which could result in the dismissal of any member of staff found to be responsible.
11. In the event that Flipnode has a reasonable belief that modern slavery is occurring in any part of its supply chain, Flipnode:
    1. will report the matter to and engage with any relevant law enforcement, government and regulatory bodies and agencies as appropriate;
    2. will expect the relevant contractor, supplier or other business partner:
       1. to be fully transparent and supply such information as Flipnode may reasonably request in relation to the issue;
       2. to use all reasonable endeavours to put in place remedial action as soon as reasonably practical with a view to ensuring that such modern slavery ceases to occur and that the victims of that modern slavery are appropriately safeguarded; and
       3. to monitor the effectiveness of the remedial action taken including the actions taken to safeguard the victims; and
       4. to report to Flipnode at reasonable intervals on the effectiveness of that remedial action and safeguarding and any further steps taken to ensure that such modern slavery ceases to occur;
    3. may, depending on the facts and the terms of the contract with the relevant contractor, supplier or other business partner, terminate or suspend the relationship or otherwise cease, reduce or minimise business contact with the relevant contractor, supplier or other business partner.
12. Flipnode’s leadership team and all members of staff are expected to:
    1. read, understand and comply with this Policy; and
    2. raise concerns with their manager, the [VP People] or any member of Flipnode’s [Management Team] about any suspicion that modern slavery might be occurring in any part of Flipnode’s business or in any of Flipnode’s supply chains at the earliest possible opportunity.
13. Flipnode wishes to encourage openness and will support anyone who raises a genuine concern that modern slavery might be taking place in any part of Flipnode’s business or in any of Flipnode’s supply chains, even if that concern ultimately turns out to be mistaken.
14. This Policy also reflects the expectations that Flipnode has of its contractors, suppliers and other business partners.

Responsibility for the Policy

15. Flipnode’s [Management Team] has overall responsibility for this Policy, including ensuring that it complies with legal and ethical obligations.
16. Flipnode’s [VP People] is primarily responsible for the day-to-day implementation of the Policy including monitoring its effectiveness and ensuring that all staff are aware of, understand and comply with the Policy.
17. All staff are responsible for following the Policy to the extent that it affects their day-to-day work and in particular in respect of the reporting requirements.
18. Flipnode’s [VP People] welcomes any questions or comments on this Policy and suggestions for ways in which it or procedures relating to the eradication of modern slavery might be adopted, adapted or improved.

Sanctions

19. Any breach of this Policy by any member of staff including in respect of their duties for Flipnode or in respect of his or her personal and domestic affairs may be dealt with under Flipnode’s disciplinary procedures and could result in dismissal.

Training

20. Flipnode provides more specific training to those members of staff through whom the steps taken by Flipnode in compliance with this Policy are most likely to be taken. The aim of the training is to ensure a high level of understanding of the nature of modern slavery and the influence Flipnode is able to bring to ensure that it does not occur within any part of its own business and in any of its supply chains.
21. Flipnode expects its contractors, suppliers and other business partners to provide similar training to their members of staff.

Amendments to the Policy

22. The Policy expresses the will of Flipnode and its commitment to the issues addressed. However, it does not in itself create any contractual obligations and may be amended by Flipnode at its discretion at any time.
23. The Policy will be reviewed by Flipnode’s [Management Team] on a regular basis.