CONSILIENT, INC. ANTI-SLAVERY STATEMENT
Introduction
The UK Modern Slavery Act 2015 (the “Act” requires businesses to state the actions they have taken during the financial year to ensure modern slavery is not taking place in its operations and supply chains.
Pursuant to section 54(1) of the Act, this statement sets out the steps taken by Consilient, Inc. to prevent modern slavery and human trafficking within its organization.
Business Structure
Consilient provides technology for the prevention of financial crime and helps businesses to discover and manage financial crime risks.
Our Supply Chains
We expect all our contractors, suppliers and other business partners to adopt the same high standard as we do to prevent modern slavery, by ensuring all employees and workers are treated with dignity and respect in a fair and ethical environment. Our procurement process includes vetting of all potential suppliers, with responses being evaluated on the basis of supplier policies and controls. We expect our suppliers to adopt the same principles when contracting with their own suppliers and plan to make this a requirement.
Our supply chains include: consultants, marketing & PR, recruitment; IT and software services; HR systems.
Our Policies on Slavery and Human Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy 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 supply chains.
Additionally we operate the following policies to describe our approach to the identification of modern slavery risks and steps to prevent slavery and human trafficking in its operations:
• Whistleblowing policy – We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organization. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
• Code of conduct — The organization’s code makes clear to employees the actions and behavior expected of them when representing the organization. The organization strives to maintain the highest standards of employee conduct and ethical behavior when operating abroad and managing its supply chain.
Recruitment, Training and Work Culture at Consilient
We are dedicated to maintaining a fair and ethical workplace for all our staff. The organization uses only specified, reputable employment agencies to source labor and always verifies the practices of any new agency it is using before accepting workers from that agency. Our Whistleblowing Policy enable concerns to be raised and resolved. Those can include any concerns about supplier practices.
It is important to us that our colleagues are aware of the issues surrounding modern slavery and support the firm’s values. We therefore intend to offer a training program for existing employees and personnel to reinforce our zero-tolerance policy and the steps to be taken in the event of any concerns.
Due Diligence Processes for Slavery and Human Trafficking
We are continuing to improve our internal processes to identify risk related to human trafficking and slavery associated with our supply base. We assess risk related to human trafficking and slavery associated with our supply base. Our preliminary assessments will be based upon geography, the product or services being purchased, supplier quality performance and the nature of the business transaction.
As part of our initiative to identify and mitigate risk we carry out due diligence on our suppliers to ensure they provide a declaration that they comply with slavery and human trafficking legislation and we provide them with our Modern Slavery Policy.
We will:
• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers.
Supplier Adherence to our Values
We expect all our contractors, suppliers and other business partners to adopt the same high standard as we do to prevent modern slavery, by ensuring all employees and workers are treated with dignity and respect in a fair and ethical environment. Our procurement process includes vetting of all potential suppliers, with responses being evaluated on the basis of supplier policies and controls.
We have a zero tolerance to slavery and human trafficking. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labor. The organization works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of this will lead to the termination of the business relationship.
We have a compliance team, which consists of involvement from the following departments:
• Audit, finance and compliance.
• Human Resources.
• Sales.
Awareness
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we ensure our staff are aware of the obligations of the Act.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Consilient Inc.’s slavery and human trafficking statement for the financial year ending 31st December 2022.
