Ingenuiti: Modern Slavery and Human Trafficking Policy
Introduction and Commitment
Ingenuiti is dedicated to upholding the highest ethical standards and respecting human rights in all aspects of our global operations. We recognize that modern slavery and human trafficking, including forced labor and unlawful child labor, are grave violations of fundamental human rights. Ingenuiti is committed to creating and maintaining a work environment that is entirely free from such practices. We will not tolerate or condone modern slavery or human trafficking within our organization or throughout our supply chains.
Scope
This policy applies to all Ingenuiti employees, subsidiaries, contractors, subcontractors, vendors, partners, and any other individuals or entities acting on behalf of Ingenuiti, wherever they are located globally.
Definitions
- Modern Slavery: Encompasses slavery, servitude, forced or compulsory labor, and human trafficking.
- Human Trafficking: The recruitment, transportation, transfer, harboring, or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labour or services, slavery or practices similar to slavery, servitude or the removal of organs.
- Forced Labor: All work or service which is exacted from any person under the menace of any penalty and for which said person has not offered himself voluntarily.
- Unlawful Child Labor: Any work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development. This includes work that is mentally, physically, socially or morally dangerous and harmful to children; and interferes with their schooling by depriving them of the opportunity to attend school; obliging them to leave school prematurely; or requiring them to attempt to combine school attendance with excessively long and heavy work.
Policy Statement
Ingenuiti is committed to:
- Preventing and prohibiting modern slavery and human trafficking in all our operations and supply chains.
- Conducting thorough due diligence on our suppliers, contractors, and partners to assess and mitigate the risk of modern slavery and human trafficking.
- Ensuring that our employees and business partners are aware of this policy and their responsibilities.
- Implementing robust monitoring and reporting mechanisms to identify and address any potential violations.
- Promoting ethical recruitment practices and ensuring that all workers are employed voluntarily and have fair terms of employment.
- Respecting the rights of all workers, including freedom of movement, freedom of association, and the right to fair compensation.
Reporting and Compliance
- All Ingenuiti employees, subsidiaries, contractors, subcontractors, vendors, partners, and others through whom Ingenuiti conducts business have a responsibility to avoid complicity in any practice that constitutes modern slavery or human trafficking.
- Any individual who becomes aware of or suspects any violation of this policy must report it immediately to the Human Resources Department or through Ingenuiti’s designated reporting channels.
- Employees who fail to report actual or suspected misconduct may be subject to disciplinary action, up to and including termination of employment.
- Ingenuiti will not tolerate any form of retaliation against any individual who reports a concern in good faith or cooperates with a compliance investigation, even if the investigation does not substantiate the report.
Investigation and Remediation
- Ingenuiti will thoroughly investigate all reports of suspected modern slavery or human trafficking.
- If a violation is confirmed, Ingenuiti will take appropriate remedial action, which may include terminating relationships with suppliers or partners, implementing corrective action plans, and providing support to affected individuals.
- Ingenuiti and its subsidiaries have the exclusive right to interpret this policy regarding their respective employees.
Continuous Improvement
Ingenuiti is committed to continuously improving its policies and practices to combat modern slavery and human trafficking. We will regularly review and update this policy to ensure its effectiveness and compliance with relevant laws and regulations.
Communication
Ingenuiti will communicate this policy to all relevant stakeholders to ensure its effective implementation.
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