Telit Cinterion Group Anti-Slavery, Child Labor and Human Trafficking Policy
Updated September 2023
To contact the Designated Officers referred to in this Policy, you can send an e-mail to email@example.com.
1. POLICY STATEMENT
- Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor 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 child labor and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and child labor is not taking place anywhere in our own business or in any of our supply chains. For the purposes of this policy, child labor has the same meaning provided by the International Labor Organization as “work by children under the age of 12; work by children under the age of 15 that prevents school attendance; and work by children under of age of 18 that is hazardous to the physical or mental health of the child”.
- We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery and child labor throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labor, or anyone held in slavery or servitude, whether adults or children, and child labor 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, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
- This policy does not form part of any employee’s contract of employment, and we may amend it at any time.
2. RESPONSIBILITY FOR THE POLICY
- The board of directors of Telit Cinterion has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it, including all other companies in the Telit Cinterion group.
- The Compliance Officer has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery and child labor.
- Management at all levels are responsible for ensuring that those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery and child labor in supply chains.
- You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Designated Officers.
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 and child labor 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.
- If you believe or suspect that modern slavery or child labor is taking place anywhere in our own business or in any of our supply chains, or that any other breach of this policy has occurred or that it may occur, you must notify the Designated Officers as soon as possible at: firstname.lastname@example.org.
- You are required to raise concerns about any issue or suspicion of modern slavery or child labor in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
- 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 or child labor, raise it with the Designated Officers at: email@example.com.
- The Designated Officers are:
- Telit Cinterion’s Compliance Officer;
- and The Chairman of Telit Cinterion’s Audit Committee
- The Designated Officers are:
- 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 or child labor of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Compliance Officer immediately.
4. COMMUNICATION AND AWARENESS OF THIS POLICY
- Training on this policy, and on the risk our business faces from modern slavery and child labor in its supply chains, forms part of the induction process for all individuals who work for us (where appropriate), and regular training will be provided as necessary.
- This policy must be communicated to all persons working for us or on our behalf in any capacity.
- Our zero-tolerance approach to modern slavery and child labor must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
5. BREACHES OF THIS POLICY
- Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
- We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.