Modern Slavery and Human Trafficking Statement

Structure and supply chains

All SmartWork staff have a personal responsibility for maintaining a respectful work atmosphere, free of abusive or unprofessional conduct. Every employee is expected to respect other people and treat them with dignity.

Responsibility for SmartWork’s anti-slavery initiatives is as follows:

• Policies: Legal Counsel is responsible for creating and reviewing policies. The process by which policies are developed is by looking at best practices and adapting to the needs of SmartWork.


• Risk assessments: Legal Counsel is responsible for risk assessments in respect of human rights and modern slavery.


• Due diligence: Legal Counsel is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.

Policies on modern slavery

SmartWork believes everyone should have the opportunity to work. SmartWork complies with all applicable employment laws and our obligation is to ensure fairness in the hiring and advancement of all employees, both permanent and temporary without discrimination.

SmartWork’s commitment to respect in the workplace includes full support for international efforts to promote ethical principles and practices related to the prevention of the exploitation and abuse associated with modern slavery and human trafficking.

SmartWork is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.

SmartWork also expects a commitment to these principles from all organisations with which business is conducted and will not support or do business with any organisations knowingly involved in slavery or human trafficking.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

• Reporting – the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.


• SmartWork Code of Business Ethics – This sets down the actions and behaviour expected of employees when representing SmartWork.


• Environmental Policy – This summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities.


• Due Diligence Processes for Slavery and Human Trafficking



SmartWork undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. SmartWork’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners and evaluating the modern slavery and human trafficking risks of each new supplier and invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.



Risk Assessment


SmartWork performs a risk assessment to assess the risk in respect of human rights and modern slavery through a review of its own practices and that of its supply chains. The risk assessment is reviewed regularly and no less frequently than annually.



Measuring effectiveness


SmartWork uses the key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains requiring all staff to have completed training on modern slavery as part of equality and diversity training.



Training


To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires staff to complete equality and diversity training on induction and every 3 years thereafter.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary.

This Modern Slavery and Human Trafficking Statement has been approved and authorised by:


Pank Koria
Managing Director


21 February 2022