Modern Slavery and Human Trafficking Policy

Scope

This policy applies to all ecoPortal employees, contractors, interns, directors, and third parties working on our behalf. It also applies to our suppliers, partners, and any entity within our upstream or downstream value chain that provides goods or services to ecoPortal.

Definitions

Modern slavery: Umbrella term covering slavery, servitude, forced or compulsory labour, debt bondage, deceptive recruitment, forced marriage, child labour that is exploitative or interferes with schooling, and human trafficking.

Supply chain: Any external party providing goods or services used by ecoPortal to develop, deliver, or support our products and operations, including software, cloud services, consultants, and office services.

Policy Statement

Governance & Responsibilities

• Executive Team: Provide oversight, approve policy, and review risk posture and remediation progress.

• Chief Executive Officer: Accountable executive owner for modern slavery risk management and annual statement approval. @Manuel Seidel

• People & Culture (HR): Integrate controls into hiring, screening, onboarding, training, grievance channels, and disciplinary process. @Beks Vilitau

• Procurement/Vendor Management: Conduct supplier due diligence, include contractual clauses, monitor performance, and escalate issues. @Beks Vilitau

• Security & Privacy: Align data handling, access, and incident response when investigations involve personal data. @Daniel Alexander

• All Employees and Contractors: Complete training, follow this policy, and report concerns.

Risk Management Approach

We apply a risk-based framework to identify and mitigate modern slavery risks, prioritising higher-risk categories, geographies, and service types.

• Risk identification: Map key categories (e.g., contracted services, cloud/IT providers, office services, hardware manufacturing, marketing/print, travel and logistics).

• Risk assessment: Use criteria such as country risk, industry risk, labour intensity, subcontracting tiers, recruitment practices, and audit history.

• Prioritisation and treatment: Apply proportionate controls (enhanced due diligence, contract clauses, corrective action plans, or disengagement if unresolved).

Supplier Standards & Due Diligence

All new and existing suppliers must meet ecoPortal’s Supplier Standards and are subject to ongoing due diligence and monitoring.

• Pre-engagement screening: Modern slavery questionnaire, policy verification, grievance mechanism availability, and subcontractor oversight.

• Contractual requirements: Prohibit forced labour, child labour (below legal minimum age), recruitment fees, document retention, and restrictions on freedom of movement; require right to audit, disclosure of subcontracting, corrective action cooperation, and termination for breach.

• Ongoing monitoring: Periodic attestations, issue tracking, risk-triggered assessments, and independent audits where warranted.

Employment Practices at ecoPortal

• No recruitment fees: Workers shall not pay for a job; any fees are borne by ecoPortal or our agents.

• Right to work and freedom of movement: We never retain passports or identity documents and respect lawful notice and resignation rights.

• Fair wages and hours: Compensation meets or exceeds legal minimums; working hours, leave, and overtime comply with local laws and are transparent in payslips.

• Young workers: We prohibit child labour and provide additional protections for legal young workers (e.g., limits on hazardous tasks).

• Safe workplace: Consistent with our Code of Conduct and Health, Safety, and Wellbeing commitments; no harassment, intimidation, or retaliation.

Grievance, Reporting & Whistleblowing

We encourage internal and external stakeholders to report suspected modern slavery or human trafficking, anonymously where permitted.

• Internal channels: Report to People & Culture, your manager, or Security & Privacy. For security/privacy incidents, email issues@ecoportal.com consistent with our Information Security Policy.

• Supplier channels: Vendors must maintain accessible, confidential grievance mechanisms and communicate these to workers.

• Non-retaliation: Reporters acting in good faith are protected from retaliation under our Code of Conduct and HR policies.

Response & Remediation

When concerns are raised, ecoPortal follows a structured process to assess, mitigate harm, and drive corrective actions.

1. Triage and safeguard: Secure immediate safety of affected individuals and preserve evidence.

2. Investigate: Coordinate HR, Legal, and Security & Privacy to determine facts, involving external experts or authorities as required by law and risk.

3. Remediate: Require corrective action plans, reimbursement of any recruitment fees, contract amendments, or temporary suspension/termination of the supplier relationship.

4. Learn and prevent: Update risk assessments, training, and controls; report outcomes to executive leadership and the Board.

Training & Awareness

Mandatory training will be provided at onboarding and refreshed at least annually for employees in risk-exposed roles (Procurement, HR, Finance, Facilities, Product & Engineering leadership). Training covers red flags, reporting, and responsibilities.

Documentation, Records & Privacy

• Maintain due diligence records, risk assessments, supplier attestations, investigations, and remediation actions in secure systems aligned with our Access Control and Information Security Policies.

• Handle personal data in accordance with our GDPR Compliance Policy and applicable privacy laws; collect only what is necessary and proportionate.

Public Disclosure & Statements

Where legally required or appropriate, ecoPortal will publish a Modern Slavery Statement describing risks, actions taken, and effectiveness measures. The statement will be approved at the appropriate executive level and made accessible on our website or request.

Measuring Effectiveness

We track and review:

• Supplier coverage: Percentage of suppliers screened and under contractual commitments against modern slavery.

• Incidents and remediation: Number of reported concerns, time to triage and close, and remediation outcomes (e.g., fee reimbursements, CAPs implemented).

• Training completion: Uptake and assessment results for relevant staff.

Roles & Contacts

Related Policies & References

• Code of Conduct – behavioural standards, reporting, non-retaliation.

• https://ecoportal-projects.atlassian.net/wiki/spaces/EP/pages/863731750

• https://ecoportal-projects.atlassian.net/wiki/spaces/EP/pages/882343949

• https://ecoportal-projects.atlassian.net/wiki/spaces/EP/pages/860684291

• https://ecoportal-projects.atlassian.net/wiki/spaces/EP/pages/1036353542

Review, Exceptions & Enforcement

• Review cadence: This policy will be reviewed regularly to ensure ongoing effectiveness and legal compliance.

• Exceptions: Any exception must be documented, time-bound, risk-assessed, and approved by the policy owner and a member of the Executive Team.

• Violations: Breaches may result in disciplinary action up to termination and/or disengagement of suppliers, consistent with our HR and Procurement processes.

Implementation Checklist

• Publish Supplier Standards and modern slavery clauses in standard contracts and purchase orders.

• Roll out onboarding and annual refresher training to in-scope roles; track completion rates.

• Integrate screening questions and risk flags into vendor onboarding workflows; store evidence securely.

• Establish and publicise reporting channels for workers and suppliers; ensure non-retaliation.

• Define escalation paths and corrective action plan templates; align with incident response.

FAQs