Statement of Anti Slavery & Human Trafficking

Introduction

This policy sets out to understand all potential modern slavery and human trafficking risks related to business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in own business and its supply chains. Refteck Solutions maintains relationships with many different organisations in its supply chain, as well as directly employing number of people. In the light of the general law on employment and human rights and more specifically, the Modern Slavery Act 2015, our company is absolutely committed to preventing slavery and human trafficking in its corporate activities and ensuring that its supply chain is free from slavery and human trafficking.

Organisational Structure and Supply Chains

This policy covers all the activities of Refteck Solutions and its subsidiaries. It governs all our business dealings and the conduct of all people or organisations with whom we contract directly or who we appoint to act on our behalf. Same we expect all who have, or seek to have, a business relationship with Refteck and/or any member of our organisation, to familiarise themselves with our anti-slavery policy and to act at all times in a way which is consistent with our anti-slavery policy. Company currently operates in the following countries: United Kingdom, India, Canada, and USA.

Responsibility

The Management will liaise with other relevant departments such as the HR & Admin, Logistics and Trading teams to ensure that risk analysis and investigations/due diligence in relation to modern slavery and human trafficking is carried out as required. HR and the Training Department will ensure that employees are given adequate and regular training on the issue of modern slavery so that everyone understands and complies with this policy.

Relevant Policies and Practices

Refteck Solutions operates the following policies and practices that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations. The company’s policy on DRD (Direct Report to Director) encourages all its workers, customers/clients and other business partners to report any concerns related to the direct activities of the organisation or its supply chain. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. This company’s policy procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. Employees who have concerns can directly report to the director of the company by mail or meet directly. The nature of the complaint will determine the next course of action. We endeavour to carry out our own recruitment activities and/or to only use reputable employment agencies to source labour and we carry out appropriate background checks. Personnel responsible for the recruitment activities in any of the subsidiaries are advised to adhere to this policy by ensuring that strict verification of potential employee’s right to work is carried out before any offer of employment is made. Refteck Solutions expects its subsidiaries and all supply chain to adhere to recruitment practices that ensure that all terms of employment are voluntary. Where necessary and if required, we may request demonstration of compliance with this policy. This policy on modern slavery will be communicated to all suppliers, contractors and business partners at appropriate points during our business relationship with them and reinforced as appropriate thereafter.

Our Effectiveness in Combating Slavery and Human Trafficking

We use the following Key Performance Indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains: Completion of House Audits by Area Managers and Business Development Managers; Use of labour monitoring and payroll systems; and Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations.

Breaches of this Policy

Any employees who breach this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

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