Introduction
The Customs Plus Human Rights and Anti-Slavery Statement.
CustomsPlus, (“The Company”) is committed to respecting and valuing human rights on a global scale. Operating ethically and respecting employees, customers, and stakeholders are fundamental core values at the heart of CustomsPlus corporate culture.
On October 29th, 2015, the United Kingdom Modern Slavery Act (“Act”) came into effect, putting a new focus on preventing slavery and human trafficking, Pursuant to the Act’s provisions, the following statement presents the analysis and steps CustomsPlus has taken to prevent, detect, and remediate human trafficking and modern slavery it its global business.
CustomsPlus is a cutting edge Software Development & Data Processing Company and is based in the United Kingdom. Offering a set of integrated compliance Apps to deal with the complexities of today’s supply chains.
CustomsPlus ability to structure operations around customers’ KPIs and robust industry experience helps the Company to stay focused on specific logistics needs, deliver value-added service, and run its business in an environmentally conscious way. This Modern Slavery Statement applies to the activities of CustomsPlus and any of its affiliates.
CustomsPlus Policies and Supply Chain Relationships
CustomsPlus continually strives to clearly communicate its human rights policies and expectations to its customers, third party suppliers, and agents. As a software development & data processing company, CustomsPlus does not inherently produce or manufacture products. In providing software development & data processing services, it is imperative to ensure employees andthird parties are alert to the relevant human trafficking legislation, and aware of CustomsPlus internal policies that promote human rights and the fight against the proliferation of human trafficking and modern slavery
CustomsPlus is focused on measures designed to eliminate human trafficking and achieve compliance with CustomsPlus ethical and operational standards.
CustomsPlus communicates ethical business practice expectations and standards to our employees, customers, and suppliers. These are incorporated into all the Company’s policies and procedures alongside CustomsPlus continuedcommitment to promoting an ethical corporate environment and complying with all laws, including those prohibiting human trafficking, slavery, forced labour, child labour, and unfair wages.
Due Diligence & Auditing
As part of its' compliance program, audits and reviews are conducted bi-annually in order to highlight specific risks, associated mitigating measures, and red flags. Furthermore, CustomsPlus will look to implement a due diligence program to ensure that high risk third parties operate in compliance with all applicable laws (including corruption and human trafficking) and employs a global restricted party screening policy.
Training & Awareness
As part of their induction, all CustomsPlus managers and employees are required to complete induction training covering the reporting of red flags and potential concerns on human trafficking and forced labour. Additional human rights training isprovided to employees when warranted.
Risk Assessment and Continued Risk Management
CustomsPlus management team supports the Company in identifying and mitigating trade compliance risks and includes human trafficking in its risk profile and diligence process. CustomsPlus has established reporting mechanisms, such as grievance procedures for employees to report human trafficking and forced labour concerns, which would be diligently investigated.
Relevant policies
CustomsPlus operates the following policies that describe its approach to the identification of modern slavery risks and steps to prevent slavery and human trafficking in its operations:
Whistleblowing policy: CustomsPlus encourages all its employees, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of CustomsPlus. This includes any circumstances that may giverise to an enhanced risk of slavery or human trafficking.
Employee Grievance Procedure: CustomsPlus grievance procedure enables employees to report any possible cases of slavery or human trafficking in order to secure the highest standards of conduct and ethical behaviour when operating and managing its supply chain.
Recruitment and Selection Policy: CustomsPlus uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency by demanding signature by an authorised person of a declaration regarding their policies on modern slavery and human trafficking, forced labour, child labour and unfair wages before accepting employees from that agency. CustomsPlus is committed to preventing the use of slavery in our business and our supply chain andencourages employees to look out for signs of slavery and report to relevant manager immediately, e.g., (a) physical and psychological abuse; (b) restricted movement; (c) poor living conditions; and (d) lack of personal belongings, such as their passport.
Performance indicators
CustomsPlus has reviewed its key performance indicators (KPl’s). As a result, CustomsPlus will:
• At induction and whenever deemed appropriate after that time, requiring all staff, supply chain managers and HR professionals to review and refresh their understanding of CustomsPlus policy on modern slavery;
• Introduce and apply a system for supply chain verification whereby CustomsPlus evaluates potential suppliers before they enter the supply chain; and
• review its existing supply chains whereby CustomsPlus evaluates all existing suppliers
Summary Conclusion
CustomsPlus does not tolerate any violations of human rights laws by its employees and has established remedial measurescontained in their various HR and operational policies to include suspension and/or removal of employees found in violation. CustomsPlus will continue to update its policies and procedures as required to ensure that the Company maintains the highest level of integrity and respect for all its employees and those employed within its supplychain, across its business operations as well as its supply chain.
This statement has been approved by the Board of Directors of CustomsPlus Limited.
Signed
S McGough, Director
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