MODERN SLAVERY & HUMAN TRAFFICKING STATEMENT
This statement is made for and on behalf of NMNTI. It sets out the overall commitment and steps taken by NMNTI to ensure that slavery and human trafficking are not present in our business or supply chain.
- Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory 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 and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.
NMNTI is not aware of any allegations of human trafficking/slavery activities against any of our current suppliers. If such allegations arise, we will immediately conduct an inquiry and report it to the authorities where required.
Our Supply Chain
Our key suppliers typically provide us with components for our patented TruPro® technology and approach. We do not tolerate slavery and human trafficking within our supply chain and would seek to terminate our relationship with a supplier where evidence of the same occurred.
While we believe that we work in a sector where modern slavery and human trafficking are particularly low risk, every company is at risk of being involved in some way through its operations and supply chain and we want to work with suppliers who are aligned to our values. We are committed to ensuring that there is no slavery or human trafficking arising in any part of our business or in relation to those with whom we conduct business.
Policy Statement
Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited.
NMNTI is committed to ensuring that there is no modern slavery or human trafficking in our operations or supply chain. Our Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.
Commitments
NMNTI is committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, and we expect that our suppliers will hold their own suppliers to the same high standards.
This Policy applies to all persons working for us or on our behalf in any capacity and it does not form part of any employee's contract of employment, and we may amend it at any time.
NMNTI is a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
- The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this Policy.
- We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
Risk Assessment
NMNTI takes a risk-based approach to our contracting processes and keeps them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Consistent with our risk-based approach, we may require the following:
- The monitoring and review of the effectiveness of our internal policies and their implementation.
- Supplier risk assessments on proposed service providers.
- Those willing to support an inclusive, open and tolerant workplace environment; and
- Those relating to raising concerns or poor practices by our employees and those with whom we deal (including an anonymous reporting hotline).
NMNTI intend to take the following further steps to combat slavery and human trafficking:
1. Risk assess all new suppliers and ask them to certify that they have taken steps to eradicate modern slavery within their own organisation and supply chain.
2. Notify all existing suppliers of our expectations and their obligations in relation to the prohibition of modern slavery.
3. Incorporate anti-slavery and human trafficking obligations into procurement agreements and subcontracting arrangements on a risk-assessed basis.
4. Include appropriate measures in our due diligence processes for sourcing suppliers, subcontractors and acquisitions on a risk-accessed basis.
5. Provide training to relevant Group employees to ensure a high-level understanding of the risks of modern slavery and human trafficking; and
6. Where appropriate, we will include a reference to the Modern Slavery Act 2015 in our policies and procedures.
Management at all levels is responsible for ensuring those reporting to them understand and comply with this Policy and are given any required training.