SLAVERY AND HUMAN TRAFFICKING POLICY

This policy outlines the efforts Webgains will make to seek to eradicate human trafficking and slavery from our supply chains.

The Company opposes any use of slavery or human trafficking in the manufacture and distribution of products and fully supports the promotion of ethical and lawful business practices within our workplace.  The Company will not tolerate or condone any form or practice that constitutes human trafficking or slavery in any part of our business.

The Company acknowledges responsibility to the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation.

Definition of Slavery and Servitude Slavery:  in accordance with the 1926 Slavery Convention, is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised. Since legal ‘ownership’ of a person is not possible, the key element of slavery is the behaviour on the part of the offender as if he/ she did own the person, which deprives the victim of their freedom. Servitude is the obligation to provide services that is imposed by the use of coercion and includes the obligation for a ‘serf’ to live on another person’s property and the impossibility of changing his or her condition.

Definition of Forced or Compulsory Labour: Forced or compulsory labour is defined in international law by the ILO’s Forced Labour Convention 29 and Protocol. It involves coercion, either direct threats of violence or more subtle forms of compulsion. The key elements are that work or service is exacted from any person under the menace of any penalty and for which the person has not offered him/her self voluntarily.

Definition of Human Trafficking: An offence of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job or may be a child who is influenced to travel by an adult. In addition, the exploitation of the potential victim does not need to have taken place for the offence to be committed. It means that the arranging or facilitating of the movement of the individual was with a view to exploiting them for sexual exploitation or non-sexual exploitation.

The Company is committed to driving out acts of modern day slavery and human trafficking within its business and that from within its supply chains, including sub-contractors, and partners.

The Company’s suppliers are an important part of our success and our culture. We expect each of these business partners to conduct their business with the same commitment to ethical business practices as us. The workplace practices that we expect from our suppliers include:

• Suppliers are not to use slave labour, illegal child labour or forced labour.
• Suppliers will ensure that the overall terms of employment are voluntary.
• Suppliers shall follow all local applicable laws pertaining to minimum age requirements, wages, overtime and benefits.
• Suppliers shall follow all local applicable laws pertaining to the number of hours worked in a seven (7) day week.
• Suppliers will periodically certify that they conform to the expectations described above and that all materials incorporated into their products comply with the laws regarding human trafficking and slavery of the country or countries in which they are doing business.

Suppliers must be able to demonstrate compliance with this Policy at the request and satisfaction of the Company.  The Company will conduct internal verification of product supply chains to evaluate and address risks of human trafficking and slavery.

The Company will maintain internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and human trafficking.  The Company will promptly and thoroughly investigate any claim or indication that a supplier is engaging in human trafficking or slave labour. If a supplier is found in violation of this policy, the Company will take prompt, remedial measures to address the violation.

The company will not support or deal with any business knowingly involved in slavery or human trafficking. The company Directors and senior management shall take responsibility for implementing this policy and its objectives and shall provide adequate resources (training etc.) and investment to ensure that slavery and human trafficking is not taking place within the Company and within its supply chains.

A full copy of this policy and a copy of the Modern Slavery Act 2015 will be accessible to all employees electronically and can be obtained from the HR department upon request.

This policy statement will be reviewed annually and published.