The Assent Compliance Platform How to Mitigate Human Trafficking & Child Labor Risk in Your Supply Chain

THE ASSENT COMPLIANCE PLATFORM HOW TO MITIGATE HUMAN TRAFFICKING & CHILD LABOR RISK IN YOUR SUPPLY CHAIN

1 THE ASSENT COMPLIANCE PLATFORM HOW TO MITIGATE HUMAN TRAFFICKING & CHILD LABOR RISK IN YOUR SUPPLY CHAIN

ABOUT ASSENT Assent takes a multi-tiered approach to providing Assent provides a full compliance program capturing online tools, applications and consulting to clients in due diligence expectations to satisfy a company’s a variety of sectors. We combine a foundation in IT legal and internal policy requirements towards an- with regulatory consulting and project management ti-human trafficking measures. This full compliance to provide solutions that address the ever-changing program can be used to satisfy other anti-human landscape of regulatory compliance needs. We are a trafficking laws (i.e. California’s Transparency in the progressive organization that stays on the forefront Supply Chain Act and the UK Modern Slavery Act). of fluid regulations in order to help our clients adapt their strategies quickly and cost effectively. Our goal This compliance program has been developed using is to implement solutions that allow our clients to specific subject matter expertise from Verité – the focus their resources on their core business rather leading anti-human trafficking NGO that is preparing than compliance issues by instituting proactive ini- the Federal Acquisition Regulation (FAR) Guidance tiatives that simplify the compliance process. for the U.S. Government.

CORE AREAS OF EXPERTISE APPROACH TO MONITOR »» Regulatory Compliance and Consulting & DETECT »» Ethical Sourcing, Conflict Minerals, Restricted The Federal Acquisition Regulation requires that Substances and Inspections firms develop a system to monitor and detect human »» IT Solutions and Development trafficking activities pursuant to clauses 52.222-50 / 52.222-56. It is Assent Compliance’s position that »» Project Management and Solution Integration to be compliant with FAR 50/56 it is essential that a firm is proactive in their due diligence. ABOUT HUMAN TRAFFICKING The Assent Compliance program and methodology outlined in this guide was developed in conjunction Human trafficking has become a global epidemic. with industry leading experts, including Verité. The dramatic increase of these illicit activities world- wide has led to the Department of Defense (DOD), The Assent program is proactive and preventative in the National Aeronautics and Space Administration nature rather than being a reactive program similar (NASA) and the General Services Administration to a world information crawler that provides alerts. (GSA) to publish the final anti-human trafficking rule We are preventative in that our system preemptively amending the current Federal Acquisition Regulation creates risk profiles of your suppliers. It acquires data (FAR) provisions. These amendments increase re- from your global supply chain based off of a credible sponsibilities for companies doing business with the and consistent process developed with guidance U.S. Government.

2 from partner NGOs, internal subject matter experts Assent will gather subcontractor declarations of and government guidance. It also narrows the focus conformity for identified subcontractors, provide of monitoring and detection, allowing you to focus verification analysis and convert proprietary- sub resources and energy on real risks. contractor declaration information into a single, client-based format. This allows our clients to accept Relying solely on reactive detection through the media a wide range of different subcontractor formats (pdf, and sanction lists only ensures human traffickers word, excel, etc.), while still being able to generate the time and space needed to securely conduct their risk analysis reports and cross-reference different illicit activities. One of the benefits of the Assent subcontractor information. These features enable program is the built-in mitigating factors that varying subcontractor declarations to be rolled up authorities will be looking for in the case of a potential into prime contractor and contracting officer level violation. Demonstrating that you actively pursued reporting needed for anti-human trafficking verifica- your supply chain for information in an effort to tion requirements. uncover any issues, alongside passively monitoring the world sanctions lists, will be viewed extremely All of the information above is made available inter- favourably if demonstration of your due diligence is nally in Assent’s system and through report extracts required. for proof of due diligence as required for anti-human trafficking audits. Assent Compliance believes that our program of active and passive monitoring and detection is vital for compliance with the FAR clauses, California Transparency in Supply Chains Act and the UK’s Modern Slavery Act.

SOFTWARE & SUPPORT SERVICES The Assent Compliance Platform is a fully customizable, cloud-based software solution which enables our clients to achieve regulatory compliance, monitor and maintain their regulatory compliance status and implement a wide range of anti-human trafficking control programs. This allows for automatic updates as regulations are revised and new products are added to the system in order to provide real-time documentation of due diligence and regulatory conformity. All of the information generated by the Assent system can be fully integrated with your existing PLM/ERP systems.

Assent will provide education and training via As- sent University to internal users and subcontractors regarding anti-human trafficking compliance and introduce subcontractors to a portal where they can submit their declaration information directly to As- sent’s database.

3 ANTI-HUMAN TRAFFICKING MODULE INTERFACE

OVERVIEW The Assent Compliance Platform Anti-Human Traf- ficking Module was designed to ensure all aspects of our clients programs have clear visibility into the operations, activities and hiring practices, including migrant worker recruitment, of their supply chain. The following images provide a sample of the module’s various included features.

On initial login to our system you are presented with a comprehensive dashboard view, showing up-to-date data on how your campaigns are performing for survey send-outs to your supply chain.

4 ANTI-HUMAN TRAFFICKING SUPPLIER LIST & DETAILED SUPPLIER VIEW

This screen displays a list of every one of your suppliers who are in-scope for Assent’s Modern-Slavery and Anti-Human Trafficking survey.

The Detailed Supplier View gives you a deep look at every supplier in your supply chain. With a heads up view of their stage in our survey process, overall status of company for risk level, user and audit logs, and our monitor and detection report for each company.

USER TAB & AUDIT LOG TAB

The User tab shows you who at the supplier’s company has received an email and filled it out.

The Audit Log tab shows you the record* of all actions taken to determine the risk calculation.

* Data has been simulated as representation of actual data.

6 SUPPLIER SURVEY (PARTIALLY COMPLETED)

This is what suppliers see when they accept the link emailed to them to take our survey. Suppliers can comment and ask questions on each of our survey questions. In case something is unclear, they want more details, and/or further details on how to respond, they can click the chat bubble and post a question related directly to that survey response.

EMAIL ALERTS & NOTIFICATIONS

Our system has many controls for setting up email alerts based on the responses you receive from our survey as well as our monitor and detection methods.

You can customize the frequency of alerts via: »» As-it-happens alerts; »» Daily rollup; »» Weekly rollup; »» Monthly rollup.

As well as customize via severity of alert, for example: »» Notify me as-it-happens for High Risk cases; »» Notify me with a Monthly rollup for Low Risk cases; »» Notify me with a Weekly rollup for Medium Risk cases; »» Notify me as-it-happens for monitor and detection alerts of medium or higher risk.

7 that the relevant supplier go through a more in-depth ANTI-HUMAN assessment process with one our partner NGOs.

TRAFFICKING The survey assesses risk of modern slavery and SURVEY GUIDANCE human trafficking using the following framework: Assent Compliance’s anti-human trafficking and The supply chain environment: modern slavery risk and compliance assessment survey enables clients to track compliance and to »» Geographical location(s)/countries identify areas in their supply chain where there is »» Industry or sector likely a higher risk of human trafficking and forced labor occurring, and/or remaining undetected, linked »» Workplace characteristics to supply chain environment and characteristics Practices and policies (locations, industries, workforce characteristics, industry/sector) and to the practices, policies, agree- A supplier/service provider’s internal practices and ments and requirements in place within the supply policies around: chain. Assent Compliance has developed this risk a. Recruitment practices and use of labor recruiters assessment survey based on reports, research and b. Auditing resources from recognized expert sources in the field of forced labor and human trafficking such as the c. Prohibition of withholding employee ID and International Labor Organization, the U.S. State De- immigration documents partment Trafficking in Persons reports, Verité and d. Employee grievance mechanism/reporting others. These resources provide guidance on prac- process tices and conditions that are indicative of higher risk e. Employee agreements of modern slavery. As a supplier moves through the survey, they will have access to references, guidance f. Wage and payment practices notes, information and further guidance. g. Housing and return transportation

Once the survey has been completed by the supplier, A supplier/service provider’s requirements and they will receive a risk assessment report outlining agreements with their suppliers/service providers and explaining identified areas of risk based on their and labor recruiters. answers. Along with these identified risk areas, we will provide associated corrective actions, resources and trainings through Assent University to support suppliers in establishing and strengthening mea- RISK MANAGEMENT sures to prevent and respond to human trafficking OVERALL RISK and forced labor within their supply chain. Using Assent’s proprietary survey methodology we Through our platform, Assent clients will access are able to provide an accurate risk calculation for rates of completion of the survey for each supplier, every supplier you do business with. Once these risk risk reports, corrective actions put forward as well as levels are identified, examples of the types of actions supplier progress in implementing corrective actions that Assent will take are described below for each and completing training. level. In cases where our assessment identifies high risk across all categories and subcategories (as ex- LOW OVERALL RISK plained below) covered by this survey, it is Assent The supplier is provided with a report explaining their Compliance’s strong recommendation to our clients low risk level status, as well as access to resources

8 and guidance on best practices and recommenda- Furthermore, clients will be able to choose to include tions for Assent University training. monitoring and detection services, which would serve as another means of collecting supporting MEDIUM OVERALL RISK evidence, and double-checking the veracity of their Assent has the in-house expertise and capacity to supplier survey answers. For instance, if a supplier help customers reduce their risk if they fall within has indicated they never use third party labor recruit- this category. Our software will provide automati- ers, the monitoring and detection services could be cally-generated corrective actions to suppliers and used to verify this. trainings based on their answers to the survey. Once they complete these corrective actions and follow recommended or mandated trainings, their risk level TRACKING CORRECTIVE ACTIONS will be recalculated and they should move to the low Our software will send reminders to suppliers about risk or Medium ‘Mitigated’ categories. If they fail to corrective actions and will track their progress in take action to mitigate their risk after repeated fol- implementing corrective actions. This progress will low-up, Assent Compliance’s recommendation will be documented and clients can use this information be that they be flagged as high risk and be referred to feed into their legal disclosure requirements under to one of our partner organizations with specific sub- the California Transparency in Supply Chains Act and ject matter expertise, like Verité, for a more in-depth the UK Modern Slavery Act. assessment.

HIGH OVERALL RISK COMPLIANCE STATUS It will be Assent’s strong recommendation that those suppliers that are assessed as high risk across all of In addition to assessing levels of risk of human the above categories be referred to a partner NGO for trafficking occurring within a supply chain, Assent an in-depth profile assessment. Compliance’s modern slavery solution also captures supplier compliance under the amended U.S. Federal MEDIUM ‘MITIGATED’ OVERALL RISK Acquisition Regulation, UK Modern Slavery Act and California Transparency in Supply Chains Act. This status is for suppliers who operate within an unalterably at-risk supply chain environment but Before suppliers complete the survey, the client has who demonstrate commitment to best practice in the option of sending out their policy to suppliers for preventing forced labor and human trafficking, and them to agree to. Assent Compliance will recommend have implemented all our recommended practices that clients ensure relevant legal requirements that and policies. apply to their suppliers be included in the policy itself.

CATEGORY & SUBCATEGORY RISK As suppliers move through the survey, information relevant to our clients’ FAR compliance plan, UK Calculation of risk is described at question, subcate- Modern Slavery Act Human Trafficking Statement gory and category level. and their disclosure under the California Trans- parency in Supply Chains Act will also be collected and synthesised for customers, to help them meet SUPPORTING EVIDENCE disclosure and compliance requirements.

Suppliers will be required to provide supporting Any question/answer that is relevant to FAR legislation documentation where relevant. Failure to do so compliance is highlighted. These questions and within a given timeline will impact their risk level and answers are tracked in our software to both risk associated risk management solution.

9 assessment and FAR compliance. A separate short these in their disclosures/statements FAR survey has been developed to capture remaining »» Whether their suppliers are addressing these risks aspects of FAR compliance. This FAR survey will appear after suppliers who fall under FAR have »» Number of total suppliers who have implemented reached the end of the risk assessment survey. at least one corrective action

◆◆FAR: this means compliance is applicable for »» What steps are being taken in their supply chain all suppliers that fall under FAR. to address identified risks. ◆◆FAR+: this means compliance is applicable for »» Number of suppliers who have implemented suppliers for whom customers are required to corrective actions, and what type of corrective submit a compliance plan and annual certification. actions. For instance, they can say “360 suppliers have reduced the risk of HT in their supply chains by strengthening their code of conduct/develop- COMPLIANCE & DISCLOSURE ing a fair wage and recruitment plan/improving INFORMATION AT A GLANCE their recruitment practices etc.” Assent Compliance clients will easily see and access »» Whether their suppliers are compliant with FAR the following information: »» Compliance levels for FAR and FAR+

»» Response rates »» Key areas of risk for each supplier

»» Progress »» Number of suppliers who have implemented »» How many suppliers at H/M/L risk? corrective actions

»» Overall risk levels

»» Where the main risks lie in their supply chain.

»» Overall category and subcategory risk levels: they can see for instance the main risks in their supply chain are around recruitment practices, so they can identify key areas of risk and report

10 RISK ASSESSMENT REPORTS The following risk assessment reports are samples of what the Assent Compliance Platform Anti-Human Trafficking Module will produce. These profiles are a tool companies can use to quickly assess the risk of any given supplier based upon listed historical risk factors, such as previous litigations or regulatory infractions. They include a high risk profile and low risk profile report. ACME CORPORATION

ACME CORPORATION SlaveryABC & Human COMPANY Trafficking Risk Assessment Report

RISK PROFILE: HIGH

CAUSE OF RISKS Nov 23, 2015: Human rights, Genocide, War crimes / Settlement or Suit / pet food buyers filed a class-action lawsuit alleging that ACME Corporation’s cat food was the product of slave labor associated with Thai union frozen products.

Aug 28, 2015: Misconduct / Settlement or Suit / class action lawsuit filed for allegedly knowingly allowing itscat food to contain fish from a Thai supplier that uses slave labor.

Aug 14, 2015: Business Crimes (Antitrust, Bankruptcy, Price Fixing) / Settlement or Suit / filed the class action suit against ACME Corporation India on behalf of consumers on grounds of unfair trade practices, sale of defective goods and sale of maggi oats noodles to the public without product approval.

Jun 16, 2015: Business Crimes (Antitrust, Bankruptcy, Price Fixing) / Disciplinary, Regulatory Action / maggi samples tested by various state regulatory agencies were allegedly found containing added monosodium glutamate (msg), which the company does not declare on maggi packs, along with lead beyond the prescribed limit.

Jun 1, 2015: Business Crimes (Antitrust, Bankruptcy, Price Fixing) / Complaint Filed / food safety inspectors have filed a criminal complaint against ACME Corporation’s Indian arm, after spot checks earlier that year found excess lead in some packets of maggi instant noodles.

Feb 27, 2014: Business Crimes (Antitrust, Bankruptcy, Price Fixing) / Dismissed / price-fixing class-action lawsuit had been filed against it, which later were dismissed.

Sep 30, 2013: SEC Violations (Insider Trading, Securities Fraud) / Allege / on 6 March 2010, the NY Times published its own analysis — based on information drawn from SEC records, state divestiture lists, government contracting databases, export-import bank annual reports, interior department and congressional research service documents, and the companies themselves — of 74 corporations that have done business both in Iran and with the U.S. government over the previous decade. ACME Corporation is identified on that list along with a NY Times notation that the company’s annual reports indicate it has done business in Iran since 2000.

Sep 18, 2013: Business Crimes (Antitrust, Bankruptcy, Price Fixing) / Fine - More than $10,000 / agreed to pay more than $23 million to settle a class-action lawsuit alleging price-fixing and price maintenance in the Canadian market. Deny the allegations.

Aug 2, 2013: Business Crimes (Antitrust, Bankruptcy, Price Fixing) / Probe / ACME Corporation SA and Friesland- campina — announced price cuts after authorities launched an investigation of possible price-fixing by foreign ACME CORPORATION milk suppliers. they also were accused of using vertical monopolies to raise prices. Jun 6, 2013:ABC Regulatory COMPANY Action / Disciplinary, Regulatory Action / the listed entity has had penalties imposed upon them by the Competition Bureau of Canada for violating regulations contained in the competition law, a federal law governing most business conduct in Canada that contains both criminal and civil provisions aimed at preventing anti-competition practices in the marketplace.

Dec 5, 2012: Fraud, Scams, Swindles / Settlement or Suit / the ECC won legal battles against ACME Corporation, accusing ACME Corporation of providing “false information” to “smear our products.”

May 18, 2012: Iran Connect / Associated with, Seen with / Andreas N Koopmann is serving as vice chairman of ACME Corporation India limited and also serving on the board of directors of Credit Suisse Group AG. Credit Suisse Group AG is the parent company of Credit Suisse AG. Credit Suisse AG is an affiliate of various banks of Iran such as Bank Melli, Bank Refah, Bank Mellat, etc. which are listed either in one or all of the following : Specially Designated National (SDN) list by the United States Department of the Treasury, Australian Department of Foreign Affairs and Trade (DFAT), Iran Specified Entities, consolidated list of persons groups and entities subject to EU financial sanctions, or an affiliate to Iran’s Revolutionary Guard Corps.

May 18, 2012: Iran Connect / Associated with, Seen with / Peter Brabeck Letmathe is serving on the board of directors of ACME Corporation and Credit Suisse Group AG. Credit Suisse Group AG is the parent company of Credit Suisse AG. Credit Suisse AG is an affiliate of various banks of Iran such as Bank Melli, Bank Refah, Bank Mellat, etc. which are listed either in one or all of the following : Specially Designated National (SDN) list by the United States Department of the Treasury, Australian Department of Foreign Affairs and Trade (DFAT), Iran Specified Entities, consolidated list of persons groups and entities subject to EU financial sanctions, or an affiliate to Iran’s Revolutionary Guard Corps.

Sep 15, 2011: Iran Connect / Associated with, Seen with / ACME Corporation SA is an affiliate of Alfa Laval AB. Alfa Laval AB is prohibited from contracting with public entities in California as per the Iranian Contracting Act of 2010. Furthermore, Alfa Laval AB also holds an office in Tehran, Iran.

Dec 14, 2010: Regulatory Action / Fine - More than $10,000 / this entity appears on the Greece Hellenic Competi- tion Commission’s list of decisions and resolutions.

Jun 30, 2010: Bribery, Graft, Kickbacks, Political Corruption / Allege / the named entity was identified publicly in a 30 June 2010 document leaked to Global Witness — an international NGO focused on examining the relationship of natural resources and international trade systems with corruption — that detailed western banking institutions holding Libyan oil money as well as investments by the Libyan Investment Authority (LIA) in foreign businesses. The Y Times on 26 May 2011 noted that it had independently verified the leaked document as authentic and described it as a “summary of LIA investments.” Global Witness cited the information as justification for a new law requiring banks and investment funds to disclose all managed state funds to make it more difficult for sanctioned persons or companies to move the proceeds of corruption through the global financial system.

Feb 12, 2009: Murder, Manslaughter (Committed, Planned or Attempted) / Probe / investigation into the killings

Dec 23, 2007: Business Crimes (Antitrust, Bankruptcy, Price Fixing) / Accuse / accused of price fixing,allege that ACME CORPORATION the Canadian divisions of this company teamed up in a price-fixing scheme in the multibillion-dollar Canadian chocolate bar market. ABC COMPANY Nov 29, 2007: Regulatory Action / Disciplinary, Regulatory Action / this entity appears on the Greece Hellenic Competition Commission’s list of decisions and resolutions.

Apr 10, 2007: Business Crimes (Antitrust, Bankruptcy, Price Fixing) / Charged / charged with price fixing

Jun 5, 2006: Fraud, Scams, Swindles / Accuse / accusing of customs fraud

Mar 30, 2006: Regulatory Action / Fine - More than $10,000 / this entity appears on the Romanian Competitions Council Decisions List

Aug 26, 2005: Human rights, Genocide, War crimes / Complaint Filed / the complaint filed by the ILRF alleges the defendants’ involvement in the trafficking, torture and forced labor of children who cultivate and harvest cocoa beans, which companies import from Africa

RECOMMENDED MITIGATION ACTIVITIES - Immediate action required - Contact partner organization for an in-depth assessment

CORPORATE INFO

ADDRESSES: VEVEY 1800, CH GR CA, US IN FR ZA TH DE

KNOWN ALIASES: ACME CORPORATION HELLAS S.A. ACME Corporation India Ltd ACME Corporation U.S.A. ACME Corporation Canada ACME Corporation ACME Corporation Deutschland AG

LINKS: http://www.nytimes.com ACME CORPORATION http://www.ACME Corporation.com/ http://www.ACME Corporation.in/default.aspx http://www.globalwitness.org/sites/default/files/library/Libyan%20Investment%20Authority,%20as%20of%20ABC COMPANY June%202010.pdf http://www.nytimes.com/2011/05/27/world/africa/27qaddafi.html?_r=1&hp http://www.epant.gr/apofaseis_ctg.php?Lang=gr&id=28 http://www.consiliulconcurentei.ro/en/official-documents/competition/decisions.html http://www.competitionbureau.gc.ca/eic/site/cb-bc.nsf/eng/h_00152.html

REMARK:

DECISION NO. 510/VI/2010 Government Gazette no. 589/B/14.04.2011 Case Type: Other Fines: EUR 22,340,073, EUR 7,446,691 decision no. 369/V/2007 Government Gazette no. 177/B/06-02-2008 Case Type: Ex officio inspections article.1,2 Fine: EUR 6.188.896,82

Provision of the Canada Competition Act: Chocolate Industry On the ground of the provisions of art. 50 letter a) and art. 55 par. (1) and (3) of the Competition Law no. 21/1996, republished, the undertaking Nestlé Deutschland AG of Germany is sanctioned with a fine in amount of RON 5,000 (fivethousand) for breaching the provisions of art. 15 par. (1) and (2) of the law, by failing to notify the economic concentration achieved by acquiring sole control over the undertaking Schöller Holding GmbH & Co. KG of Germany.

PEP TYPE: Dreyers Grand Ice Cream Holdings Inc, Associate Peter Brabeck Letmathe, Associate Andreas N Koopmann, Associate Andreas N Koopmann, Employee Associate of ACME Corporation SA(NESN.VX)

ARTICLE SOURCE: Greece Hellenic Competition Commission - Resolutions Romania Competition Council - Decisions The Toronto Star Iran Connect ACME CORPORATION

The Philadelphia Inquirer Canada Competition Bureau - Court Penalties ABC COMPANY LexisNexis Article - 5G75-18K1-DXJR-H3BD, The Times of India (TOI) Agence France Presse LexisNexis Article - 5HFK-6681-DYT4-V15N, San Jose Mercury News (California) Acquire Media Article - 201508140001HIND____MINT_____n-9102698_810.7, Mint (New Delhi) Rural News Brand Republic LexisNexis Article - 5G43-5731-DYWP-R3H8, Channel NewsAsia Associated Press Newswires Congressional Testimony by CQ Transcriptions Special Media All Africa The Bradenton Herald Acquire Media Article - 201508280224AFPNEWS_NEWS_____TX-PAR-RRT15_120.6, AFP World News

ARTICLE ID: TOR0000020130918e99i0001w PHLI000020140227ea2r0000r AFPR000020121205e8c5007nb RNRURN0020070410e34a0000d BRAREP0020050826e18q00008 APRS000020130802e982000pr CGT0000020090217e52c00002 AFNWS00020060605e26500339 BRDH000020071223e3cn0001t ACME CORPORATION

ABC COMPANY

ABC COMPANY Slavery & Human Trafficking Risk Assessment Report

RISK PROFILE: LOW RISK

Your survey answers indicate that there is a low risk of human trafficking and forced labor occurring within your supply chain.

Please note this does not mean that your supply chain is necessarily free from human trafficking and forced labor. Rather, it means the environment within which your supply chain exists, combined with the practices that you have in place to prevent human trafficking and forced labor, make it less likely for these violations to occur.

It is essential that you have a strong understanding of human trafficking and forced labor and relevant legislation. Please click here to access Assent University and complete the Modern Slavery trainings.

DETAILED STATUS EXPLANATION: Below you will find a detailed explanation of your risk status.

SUPPLY CHAIN ENVIRONMENT This section of the survey determined the level of risk of human trafficking occurring within your supply chain based on the environment within which your supply chain exists. This encompasses geographical location, type of industry or sector, and workforce characteristics.

Your supply chain environment is considered to be at low risk of human trafficking and forced labor because:

1. Your business only produces and/or sources its products or services in countries that are ranked as Tier 1 by the United States Department of State 2015 Trafficking in Persons report. Tier 1 countries are countries whose governments fully comply with the Trafficking Victims Protection Act’s minimum standards.

2. You, your suppliers, and service providers do not work within industries that are flagged as high risk for human trafficking and forced labor.

3. You, your suppliers, service providers, and labor recruiters do not recruit low-skilled workers from other countries.

YOUR BUSINESS PRACTICES This section of the survey determined the level of risk of human trafficking and forced labor occurring in your supply chain based on the practices and policies you have in place to prevent, detect and respond to these violations, as well as on the supporting evidence you have provided to prove these practices and policies are in place. ACME CORPORATION

ABC COMPANY

Your business practices represent a low risk of human trafficking and forced labor because you have established internal practices and policies that help prevent these violations and you require your suppliers, service providers and labor recruiters to also have practices and policies in place to help prevent these violations.

INTERNAL PRACTICES AND POLICIES You have indicated that:

• You recruit, select and hire all workers directly. • You have a policy or code of conduct that prohibits the charging of any recruitment fees to employees. • Independent audits are conducted at your work locations that capture fair labor practices • You have a policy or code of conduct that prohibits the withholding of employee identity and immigration documents. • You have a grievance mechanism or reporting process in place that employees can use to confidentially report cases of human trafficking or other prohibited/illegal behavior without fear of retaliation. • You have a policy in place that states that all your employees must be provided with employment agreements, including those hired by labor recruiters, and you always provide employment contracts in a language understood by the employee at least five days before the employee relocates for work. • You pay all your employees directly, you do not have access to employee bank accounts, and you have a policy requiring that you communicate method and frequency of payment to all employees prior to them relocating for work. • You have measures in place to ensure employee housing meets local housing and safety standards and you have a policy in place that states you will provide or pay for return transportation for all foreign workers who are brought into a country to work, including those recruited through labor recruiters, and including if their employment is terminated early.

SUPPLIER/SERVICE PROVIDER AND LABOR RECRUITER REQUIREMENTS

You have indicated that:

You have a policy or a clause within contract agreements requiring that your labor recruiters meet legal requirements in the country where the recruitment takes place.

You formally (through a written agreement or policy) require that all your suppliers, service providers and labor recruiters:

»» Prohibit the following

a. Human trafficking or the use of forced labor b. The charging of any recruitment fees to employees c. The withholding of employee and immigration documents »» Ensure the following ACME CORPORATION

ABC COMPANY

»» All employees are given detailed employment agreements in a language they understand, at least five days before they relocate to their place of work.

»» They pay for or provide return transportation for foreign workers who have relocated for their work, even if their contract is terminated early.

»» Employee housing provided or arranged by them must meet local housing and safety housing standards.

TRAINING Thank you for your time in completing the survey. You are a valued supplier and we appreciate your efforts in working alongside us to reduce the risk of modern slavery in our supply chains. We would like to congratulate you on your low risk survey results, and take this opportunity to emphasise that there is always room for im- provement. We want our suppliers to strive for best practice. It is essential that you and your employees have a strong understanding of human trafficking and relevant legislation and provide training to your employees on these topics.

We require that employees in the following departments of your organization complete the Modern Slavery trainings available via Assent University (click on the link to access):

»» Procurement

»» Human Resources

»» Sales

»» Corporate Compliance 5300 Canotek Road, Suite 30 Ottawa ON K1J 1A4 Canada

Toll Free: 1.866.964.6931 Fax: 1.866.391.5954 Email: [email protected]