xalts Modern Slavery Policy
Purpose and ScopeThe purpose of this policy is to communicate and establish controls to ensure compliance with all modern slavery, anti-slavery and human trafficking regulations. The policy covers all company employees, vendors and third-party service providers and is intended to ensure all are aware of the responsibilities they hold.   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 partners’.  We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our vendor, third-party service providers and business partner network. We expect the same high standards from all of our business partners, vendors and contractors.What is Modern Slavery?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.There is no typical victim of modern slavery, and some victims do not understand that they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a victim of modern slavery or human trafficking:
  • The person is not in possession of their own passport, identification or travel documents.
  • The person is acting as though they are being instructed or coached by someone else.
  • The person allows others to speak for them when spoken to directly.
  • The person is dropped off and collected from work.
  • The person avoids eye contact, is withdrawn or appears frightened.
  • The person does not seem to be able to contact friends or family freely.
  • The person has limited social interaction or contact with people outside of their immediate environment.
The above list is not exhaustive. A person may display a number of the indicators set out above, but they may not necessarily be a victim of slavery or trafficking.Our PolicyOur policy does not allow for any form of slavery or human trafficking and we will take proactive steps to ensure that modern slavery is not taking place in any part of our business. We will not engage with organisations which facilitate any form of slavery including the use of child labour or forced labour, or which do not recognise freedom of association or collective bargaining.We seek to continually improve awareness of the practices necessary to combat slavery and human trafficking and assess the risk profile of our business in these areas.Our zero-tolerance approach to Modern Slavery includes our commitment that:
  • We will not allow any form of slavery or human trafficking to take place in any part of our business.
  • We will not use child labour, nor will we use forced labour.
  • We recognise freedom of association by permitting our employees to establish and join organizations of their own choosing without our permission.
  • We will recognise collective bargaining where required by local laws.
  • We will comply with all relevant laws, statutes and regulations relating to modern slavery.
  • We will publish Modern Slavery Statements in accordance with the relevant legislation.
  • The person does not seem to be able to contact friends or family freely.
  • We require our vendors and third-party service providers to comply with the above; and to hold their own third-parties to the same standards.
  • We require our vendors and third-party service providers to comply with the above; and to hold their own third-parties to the same standards.
  • We will seek to educate and raise awareness across our business in the identification and reporting of Modern Slavery.
Compliance with the PolicyThe prevention, detection and reporting of Modern Slavery in any part of our business is the responsibility of all those working within it.We expect the highest standards of compliance to be upheld at all times. We have a robust governance structure in place and take a risk-based approach to our contracting processes which are then kept under review.We retain the right to audit our service providers’ and vendors’ activities and where practical, relationships, both routinely and at times of any reasonable suspicion. If we find that other individuals or organizations working on our behalf have breached this policy, we will ensure that we take appropriate action.Any employee who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct. If a vendor or third-party service provider is found to be in breach of this policy, we may terminate our relationship and any contract or MoU agreement in place.Reporting Modern SlaveryEmployees, vendors and third-party service providers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.If you are an employee, you must report any incidence or suspicion of Modern Slavery and/or human trafficking in any part of our business to your Line Manager and to the Chief Operating Office.If you are a vendor or third-party service provider to any of our Group entities, you should report any suspicion to your primary contact at xalts.You can confidentially report any serious concerns by email to: compliance@xalts.io. Reports are treated in accordance with our internal policies, acknowledged and acted upon as appropriate.Responsibility & ImplementationOur Board of Directors has overall accountability for ensuring that this policy complies with our legal and ethical obligations, and that all our people comply with it.The Global COO is responsible for the policy implementation and appropriate communication of this policy to all relevant employees.All enquiries or concerns regarding this policy should be communicated to our Global COO at compliance@xalts.io.All Group employees must comply with this policy. All vendors and third-party service providers must comply with this policy.The policy is available on our website https://xalts.io/ and will be reviewed on a regular basis or as required in accordance with any updates to relevant legislation.
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