Human Rights: Anti-Slavery and human trafficking
The SIERRATURK Anti-Slavery and Human Trafficking Statement
SIERRATURK has a zero tolerance towards modern slavery and is committed to opposing all forms. We expect all those with whom we have a business relationship to familiarize themselves with SIERRATURK’s position in this regard and to act at all times in a way that is consistent with this position. Modern Slavery occurs when a person is under control of another person, who applies violence and / or force to maintain that control, and the goal of that control is exploitation. Modern Slavery today takes many different forms; with bonded, child or forced labor posing the largest risk to the commodities industry.
Modern slavery is a criminal offence under the Modern Slavery Act 2015 in the USA and around the World. Modern slavery can take many forms including forced or compulsory labor and human trafficking.
As part of its commitment to combating Modern Slavery, SIERRATURK has implemented various procedures and policies. These include procedures and policies which require the conduct of due diligence on all of its potential and existing business investments and acquisitions. Additionally, SIERRATURK conducts due diligence on its business partners, suppliers and consumers. SIERRATURK has contractual provisions in its contracts which require compliance with anti-slavery laws and has various policies applicable to staff which relate to compliance with this principle. All of our employees are required to ensure that they are familiar with and comply with SIERRATURK’s position on modern slavery and human trafficking. Employees should be vigilant and aware in their dealings with suppliers and consumers and if there are any concerns or indications that there is any potential modern slavery, human trafficking or other human rights violations they should notify the compliance team immediately and before proceeding or continuing with any business activity. Additionally, the company’s whistle-blowing procedures can be followed to report such concerns.
MODERN SLAVERY COMPLIANCE
Introduction
The SIERRATURK Group. and its subsidiaries and affiliates (collectively “SIERRATURK”) is committed to ensuring that we – and our suppliers – operate in compliance with all applicable laws as well as in accordance with the highest standards of ethical behavior, as outlined in the SIERRATURK Business Code of Conduct. SIERRATURK supports and respects the protection of internationally recognized human rights and endeavors to make sure that we are not complicit in human rights abuses. Accordingly, we do not tolerate modern slavery or human trafficking in our organization or supply chain.
Our Business
SIERRATURK is a global operator in business & consumer services, critical information, analytics and expertise in forging solutions for the major industries and markets that drive economies worldwide. The company delivers next-generation information, technology, data science, analytics and solutions to customers in business, finance and government, improving their operational efficiency and providing deep insights that lead to well-informed, confident decisions. SIERRATURK has more than 50,000 key business and government customers, including Fortune Global 500 and the world’s leading financial institutions.
Our Supply Chain
SIERRATURK’s supply chain largely consists of professional services providers such as consultants, accountants, law firms, contractors, software services, and data and content providers. SIERRATURK also uses suppliers of IT, office equipment, facilities management, print production and publication distribution services.
Given the nature of SIERRATURK’s business, we believe there is minimal risk of practices that support, facilitate or are complicit with modern slavery, within either SIERRATURK or our supply chain. Nevertheless, we require that all vendors with whom we have a master services agreement agree to perform at the highest level of business and professional ethics, and to ensure that they and their subcontractors comply with all applicable anti-slavery and human trafficking laws, including but not limited to the US and UK respective Modern Slavery Acts of 2015. We have also embedded these expectations in our purchase order forms and new vendor onboarding forms.
SIERRATURK Policies on Slavery and Human Trafficking
SIERRATURK’s zero tolerance approach to modern slavery and human trafficking is confirmed in many of our corporate policies and procedures, including our Business Code of Conduct, our Third Party/Vendor Code of Conduct and our Human Rights and Labor Practices policy. These documents articulate our commitment to respecting and promoting fundamental human rights, which we view as a key component of responsible corporate citizenship. In addition to supporting the fundamental principles contained in the United Nations Universal Declaration of Human Rights, we are committed to working with suppliers to help uphold ethical human rights standards.
Due Diligence and Further Steps
SIERRATURK has determined that the majority of its suppliers operate in areas considered to be at a low risk of supporting or being complicit in forced labor or human trafficking.
SIERRATURK has implemented procedures to assess the risk of new vendors at onboarding and we require suppliers to affirm their commitment to eradicating modern slavery and human trafficking. We will undertake in the next financial year to:
- Ensure clear and effective communication with new and existing vendors regarding our commitment to compliance with the Modern Slavery Act and our zero-tolerance approach towards forced labor;
- Continue risk assessments of and, as necessary, additional engagement with suppliers;
- Continue to promote an environment that encourages reporting concerns and protects whistle-blowers.
Training
To maintain awareness and ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, all employees have been made aware of this statement and reminders will be issued on an annual basis.
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