Anti-Slavery and Human Trafficking Policy

Effective date not specified

This policy is fully endorsed and supported by the management. The policy will be amended from time to time to reflect updates and operational changes which will be communicated.

Introduction

Modern slavery is a term used to include slavery, servitude, forced and compulsory labour, bonded and child labour, and human trafficking. Victims are coerced, deceived, and forced against their free will into providing work or services. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery and human trafficking are illegal and violate fundamental human rights.

Forms of modern slavery may include, but are not limited to, withholding of passports, being forced to work against a person's will, depending on the employer for housing, food, and other necessities, being recruited through some form of debt arrangement, such as an advance or loan, and limitations on movement of workers.

We prohibit the use of modern slavery and human trafficking in our operations and supply chain. We are committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold themselves and their own suppliers to the same high standards.

Policy Statement

We expect everyone working with us or on our behalf to support and uphold the law relating to modern slavery. We have a zero-tolerance approach to modern slavery in our organisation or our supply chains. The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Users must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy. We are committed to engaging with our stakeholders and direct suppliers to address the risk of modern slavery in our operations and supply chain.

As part of our contracting processes, we include a specific prohibition against the use of modern slavery and trafficked labour and a requirement to comply with our anti-slavery and human trafficking policy, the United Kingdom’s Modern Slavery Act 2015 (as amended), the European Union’s Directive 2011/36/EU on trafficking in human beings (as amended by Directive (EU) 2024/1712) and the United States’ Trafficking Victims Protection Act 2000 (as amended) (the “Legislations”).

Our recruitment procedures require employment and recruitment agencies and other third parties supplying workers to our organisation to comply with the Legislations. Suppliers engaging workers through a third party are also required to obtain third parties' agreement to adhere to our policy.

We take a powerful stand against any form of child exploitation or human trafficking. If we discover that any Content involves underage individuals, or any form of force, fraud, or coercion, we will remove the Content and submit a report to the proper law enforcement authorities. If you become aware of any such Content, you agree to report it to this APP by contacting hello@spicestars.ai

We will terminate any person’s account and submit a report to the relevant authorities if we have sufficient reason to believe they are participating in any way in human trafficking.

Anti-Slavery and Human Trafficking Policy