At eCommfolio we take all steps to prevent modern slavery and human trafficking from taking place in our organization. We are committed to achieving high ethical standards and to acting with integrity in all areas of our business.
POLICIES, TRAINING AND WHISTLEBLOWING PROTECTION We are committed to ensuring that there is no modern slavery or human trafficking in our organization or in any part of our business. Our internal Code of Conduct and Business Ethics reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our organization. eCommfolio is proud to promote a working culture in which diversity, equality, inclusion and respect are paramount and where whistleblowing and other procedures for raising concerns are accessible and protected. All employees must read and accept the Code of Conduct and Business Ethics as part of eCommfolio’s annual compliance training.
RISK ASSESSMENT AND DUE DILIGENCE PROCEDURES eCommfolio views our industry as low-risk. Despite this, we seek to mitigate the risk of modern slavery occurring by: • Ensuring all employees have the right to work in the relevant territory in which they are employed and ensuring we comply with all local legal requirements in those territories; • Include contractual provisions in all relevant documentation to ensure compliance with all applicable laws, including modern slavery and anti-trafficking legislation; •
MEASURING EFFECTIVENESS We will review our practices annually to ensure we mitigate any risk of non-compliance with the relevant modern slavery legislations. We will continue to encourage and facilitate conversations throughout our organization to ensure any areas of risk or non-compliance are effectively identified and resolved. Our Board of Directors will review and approve this policy on an annual basis.