Anti-Slavery And Human Trafficking Policy

1. Purpose Of This Policy

   1. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour 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.
   2. ControlPlane Group Limited (“ControlPlane”, “we”, “us”) has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
   3. ControlPlane Group Limited is a limited company registered in England and Wales under company number 14149926 with its registered office at 49 Queens Road, Cheltenham, England, GL50 2LX.
   4. ControlPlane is the ultimate parent company of a group of legal entities with a corporate presence in the United Kingdom, the United States (through ControlPlane North America, LLC) and in New Zealand (through ControlPlane APAC Limited). This policy is therefore issued on behalf of ControlPlane and all entities within its group, and any reference to “ControlPlane” includes its group companies.
   5. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect and require the same high standards from all of our contractors, external consultants, third-party representatives, suppliers, and other business partners (collectively referred to here as “Associated Businesses” or individually as an “Associated Business”), and we expect that Associated Businesses will hold their own suppliers to such high standards. This policy therefore applies to all Associated Businesses.
   6. The paragraph headings contained in this policy, and their capitalisation, are included solely for convenience of reference and shall not in any way affect the meaning or interpretation of any of the provisions of this policy.

2. Responsibility For The Policy

   1. The board of directors of ControlPlane has overall responsibility for ensuring this policy complies with our legal and ethical obligations.
   2. The Chief Operating Officer of ControlPlane has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure we are effective in countering modern slavery.

3. Compliance With The Policy

   1. The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all of us.
   2. If an Associated Business believes or suspects that a conflict with this policy has occurred, or may occur in the future, they must notify ControlPlane’s Chief Operating Officer as soon as possible.
   3. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business, or in the supply chains of any supplier tier, at the earliest possible stage.
   4. Where appropriate, and with the welfare and safety of local workers as a priority, ControlPlane may give support and guidance to Associated Businesses to help them address coercive or exploitative work practices in their own business and supply chains.
   5. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

4. Responsibilities

   1. All of us have a responsibility to ensure colleagues, suppliers, contractors, and other business partners are safeguarded, treated fairly and with dignity. The Chief Operating Officer of ControlPlane will:
      1. assess the modern slavery and human trafficking risks of each new Associated Business;
      2. engage with Associated Businesses both to convey this anti-slavery and human trafficking policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses; and
      3. where possible, build long standing relationships with our Associated Businesses and make clear our expectations of their business behaviour.

5. Identifying Slavery

   1. There is no typical victim and some victims do not understand that they have been exploited and are entitled to help and support. The following list of indicators, which is not exhaustive, could trigger suspicions that someone may be a slavery or trafficking victim. The person:
      1. may not be in possession of their own passport, identification, or travel documents;
      2. will allow others to speak for them when spoken to directly;
      3. will be withdrawn or appear frightened;
      4. does not seem to be able to contact friends or family freely; and
      5. has limited social interaction or contact with people outside their immediate environment.
   2. A person may display a number of the indicators as set out above, but they may not necessarily be a victim of slavery or trafficking.

6. Breaches Of This Policy

   1. We may terminate our relationship with an Associated Business if they breach this policy.