Slavery & Human Trafficking

Xalient recognises its responsibility to take a robust approach to slavery and human trafficking.

The Company is fully committed to preventing slavery and human trafficking in its corporate activities, and ensuring that its supply chains are free from slavery and human trafficking.

Policies
The Company operates the following policies to underpin this commitment:

  • Whistleblowing policy The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
  • Employee code of conduct
    The Company’s code makes clear to employees the actions and behaviours expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when operating across the globe and managing its supply chain.
  • Procurement code of conductThe Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. 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 labour. The Company works with suppliers to ensure that they meet the standards of the code and improve their workers’ working conditions.
  • Recruitment policy
    The Company uses only reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
  • Corporate Responsibility Policy
    The Company outlines its commitment to the engagement of Suppliers and the process undertaken for checks for new employees.

 Due Diligence
The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence and reviews include:

  • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking
  • evaluating the modern slavery and human trafficking risks of each new supplier
  • reviewing on a regular basis all aspects of the supply chain
  • conducting supplier audits or assessments which have a greater degree of focus on slavery and human trafficking where general risks are identified
  • taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans if necessary
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators
The Company has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the Company is:

  • developing a system for supply chain verification, whereby the Company evaluates potential suppliers before they enter the supply chain; and
  • reviewing its existing supply chains whereby the Company evaluates all existing suppliers.