1.1 Modern slavery is a serious crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labor, and human trafficking—all of which involve the deprivation of a person’s liberty for exploitation, either for personal or commercial gain. We are committed to acting ethically and with integrity in all business dealings and relationships. Our goal is to prevent modern slavery in our operations and supply chains.
1.2 We are committed to transparency in our business and to ensuring that modern slavery is not present within our operations or supply chains. In compliance with the Modern Slavery Act 2015, we are legally required to disclose the steps we take to combat modern slavery. We expect the same high standards from all our employees and suppliers.
1.3 This policy applies to everyone working for us or on our behalf, in any capacity, including employees at all levels, directors, officers, agency workers, suppliers, seconded workers, volunteers, and interns.
1.4 This policy does not form part of any NOME SOCIETA employee’s contract of employment and may be amended at any time.
2.1 Board of Directors: The Board holds ultimate responsibility for ensuring that this policy complies with legal and ethical obligations, and that all relevant parties adhere to it.
2.2 Legal and Human Resources Departments: These departments have primary responsibility for implementing the policy, monitoring its effectiveness, addressing any queries, and auditing internal procedures.
2.3 Management: Managers at all levels are responsible for ensuring that their teams understand and comply with this policy. Guidance can be sought from the Legal and Human Resources departments.
3.1 The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of everyone working for us or under our control. You are required to avoid any activities that could lead to, or suggest, a breach of this policy.
3.2 If you believe or suspect that a breach of this policy has occurred or may occur in the future, you must inform your manager (or your main point of contact at NOME SOCIETA, if you are a supplier) immediately.
3.3 You are encouraged to raise concerns about any potential or actual instances of modern slavery within any part of our business or supply chains, including any supplier tier, as early as possible.
3.4 If you are unsure whether a specific act or working condition within our business or supply chains constitutes modern slavery, raise your concerns with your manager (or main point of contact).
3.5 We encourage openness and support anyone who raises genuine concerns in good faith, even if they are mistaken. We are committed to ensuring that no one suffers any detrimental treatment as a result of reporting concerns, such as dismissal, disciplinary action, or other unfavorable treatment. If you believe you have experienced such treatment, inform the Chief Human Resources Officer immediately. If the matter is not addressed, employees should follow the formal grievance procedure.
4.1 Guidance on this policy is included in the induction process for all individuals working with us and will be provided whenever necessary thereafter.
5.1 Employees who breach this policy may face disciplinary action, including dismissal for misconduct or gross misconduct.
5.2 We may terminate our relationship with individuals or organizations (including suppliers) who breach this policy.
6.1 This policy will be continuously monitored to ensure its effectiveness in addressing modern slavery.
6.2 The Board of Directors will regularly review this policy to ensure its relevance and effectiveness in relation to company activities.
6.3 The Company will ensure that all individuals working for or on behalf of the company are made aware of this policy.
7.1 This policy will be reviewed and, if necessary, updated in response to changes in legislation or company operations. It will also be reviewed annually to improve based on experience and feedback.
8.1 Any amendments or updates to this policy will be communicated to all relevant employees, and written notice or training may be provided where necessary.
9.1 Throughout 2022, NOME SOCIETA will continue to assess the risk of slavery and human trafficking in our supply chains and operations, taking appropriate actions and reporting as required.
9.2 This statement is made in accordance with Section 54 (1) of the Modern Slavery Act 2015 and constitutes the Slavery and Human Trafficking Statement for the financial year ending 31 December 2022.
It has been approved and authorized by the Board of Directors of NOME SOCIETA
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