Modern Slavery and Human Trafficking Policy

Audentes Fortuna is committed to preventing acts of modern slavery and human trafficking from occurring within our business operations and supply chains. This policy outlines our approach to addressing these issues.

Policy Statement

We are committed to:

• Preventing modern slavery and human trafficking in our operations
• Ensuring our supply chains are free from slavery and trafficking
• Providing training and awareness to all employees
• Maintaining transparency in our business practices
• Taking appropriate action when issues are identified

Legal Framework

This policy is based on:

• Modern Slavery Act 2015: UK legislation on modern slavery
• Human Rights Act 1998: Fundamental human rights protection
• International Labour Organization Conventions: International labor standards
• UN Guiding Principles on Business and Human Rights: Corporate responsibility
• Global Compact Principles: UN Global Compact commitments

What is Modern Slavery?

Modern slavery includes:

• Slavery: Ownership of people as property
• Servitude: Forced labor with no freedom to leave
• Forced Labor: Work performed under threat of penalty
• Human Trafficking: Movement of people for exploitation
• Child Labor: Employment of children in harmful conditions

Our Business Operations

We ensure our operations are free from modern slavery by:

• Employee Rights: Fair wages, working conditions, and freedom of association
• Recruitment Practices: Ethical recruitment and no recruitment fees
• Working Conditions: Safe, healthy, and dignified working environments
• Freedom of Movement: No restrictions on employee movement or travel
• Documentation: Proper documentation and identity verification

Supply Chain Management

We work to ensure our supply chains are slavery-free through:

• Supplier Assessment: Due diligence on all suppliers and contractors
• Contract Requirements: Anti-slavery clauses in all contracts
• Regular Audits: Monitoring and assessment of supplier practices
• Training and Support: Helping suppliers understand their obligations
• Transparency: Open communication about supply chain practices

Risk Assessment

We assess modern slavery risks in:

• Geographic Risk: Countries with high slavery prevalence
• Industry Risk: Sectors with known slavery risks
• Supplier Risk: Suppliers in high-risk categories
• Recruitment Risk: Labor recruitment and placement
• Operational Risk: Direct employment and subcontracting

Due Diligence

Our due diligence processes include:

• Supplier Screening: Background checks and verification
• Site Visits: Regular visits to supplier locations
• Documentation Review: Employment records and compliance
• Worker Interviews: Direct communication with workers
• Third-Party Audits: Independent assessment and verification

Training and Awareness

We provide training on modern slavery to:

• All Employees: General awareness and recognition
• Management: Leadership and decision-making responsibilities
• Procurement Staff: Supply chain management and assessment
• HR Personnel: Recruitment and employment practices
• Suppliers: Understanding of requirements and expectations

Reporting and Whistleblowing

We encourage reporting of modern slavery concerns through:

• Internal Reporting: Direct reporting to management
• Whistleblowing Hotline: Confidential reporting mechanism
• External Reporting: Reporting to relevant authorities
• Protection: Protection for those who report in good faith
• Investigation: Thorough investigation of all reports

Remediation

When modern slavery is identified, we will:

• Immediate Action: Stop any activities involving slavery
• Victim Support: Provide support and assistance to victims
• Legal Action: Report to relevant authorities
• Corrective Measures: Implement measures to prevent recurrence
• Monitoring: Ongoing monitoring and verification

Performance Measurement

We measure our performance through:

• Key Performance Indicators: Metrics on slavery prevention
• Audit Results: Results of internal and external audits
• Training Records: Training completion and effectiveness
• Incident Reports: Reports of slavery-related issues
• Stakeholder Feedback: Feedback from workers and communities

Continuous Improvement

We continuously improve our approach through:

• Regular Reviews: Annual review of policies and procedures
• Stakeholder Engagement: Consultation with relevant stakeholders
• Best Practice Sharing: Learning from industry best practices
• Technology Updates: Adopting new tools and technologies
• Partnership Development: Working with NGOs and other organizations

Contact Information

For modern slavery concerns or to report issues:

• Modern Slavery Officer: modernslavery@audentesfortuna.co.uk
• Whistleblowing Hotline: +44 20 XXXX XXXX
• Email: info@audentesfortuna.co.uk
• Address: London, United Kingdom