Introduction
The Anti-Slavery Policy (‘Anti-Slavery Policy’), has been established by CC7 Europe B.V. (hereinafter – the Company) to comply with the applicable laws and international acts and rules, but not limited to all other Company’s Policies and Procedures.
This Anti-Slavery Policy follows the Company’s Code of Conduct. Therefore, this Anti-Slavery Policy might be subject to review and modification as and when necessary.
Applicability
The Company has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in Company’s Projects or offices.
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.
The Company is also committed to ensuring there is transparency in business and in its approach to tackling modern slavery with disclosure obligations under the applicable laws. The Company expects the same high standards from all of the subcontractors, suppliers, vendors and other business partners, and we expect that our suppliers will hold their own suppliers to the same high standards.
This Anti-Slavery Policy applies to all persons working for the Company and Company’s projects or on our behalf in any capacity, including Employees at all levels, directors, officers, agency workers, workers for the Company’s Projects, volunteers, interns, agents, contractors, vendors, external consultants, and third-party representatives and business partners.
Responsibility for the policy
The Company has overall responsibility for ensuring the Anti-Slavery Policy complies with legal and ethical obligations and the Company’s Code of Conduct. The Company has primary and day-to-day responsibility for implementing this Anti-Slavery Policy, monitoring its use and effectiveness, dealing with any queries about the Anti-Slavery Policy, and controlling internal Company’s procedures and processes.
Compliance with the policy
The prevention, detection and reporting of modern slavery in any part of the Company’s businesses is the responsibility of all those working for the Company and Company’s Projects.
The Employees, the Company’s subcontractors, vendors, partners, must notify the CEO of the Company as soon as possible if they believe or suspect a conflict with the Anti-Slavery Policy has occurred or may occur in the future.
As part of the Company’s due diligence pre-qualification procedure and the Tender Policy, the Company vets subcontractors, vendors or business partners through a due diligence process. In terms of the Company’s supply chain, the Company is in the process of taking additional steps to strengthen the approach to due diligence and the ability to identify a risk.
Amendments
This Anti-Slavery Policy may be amended by the Company at any time. Unless otherwise specified, such amendments shall be effective from the Date of establishment of the amendments to the Anti-Slavery Policy by the CEO of the Company.