Anti-Slavery and Anti-Trafficking

Last Updated: 1 February 2023

Introduction

Contino is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking. In accordance with industry ‘best practices’ and to comply with regulations, Contino has prepared the following Anti-Slavery and Human Trafficking policy. This outlines our general duty of care to Contino employees and contractors, and the measures we will take to safeguard and ensure the wellbeing of everyone involved.

Scope

This policy extends to all employees and contractors within Contino UK and is subject to regular review and revision.

Policy Statement

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights. Contino strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation, or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

Commitments

We expect everyone working at Contino or on our behalf to support and uphold the following measures to safeguard against modern slavery:

• Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy
• We take a risk-based approach to our contracting processes and keep them under review

Consistent with our risk based approach we may require:

• Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct, produced and managed by Cognizant.
• Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code
• As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct

If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationship, through to termination of the agreement with said third party.