Slavery and Human Trafficking Statement

Modern slavery is a crime and a gross violation of fundamental human rights. It takes various forms, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Integreon has a zero-tolerance approach to modern slavery and is fully committed to preventing slavery and human trafficking in its corporate activities. Integreon is also committed to ensuring transparency in its approach to tackling modern slavery in its business and in its supply chains. At Integreon, we recognize that we all have a responsibility to be alert to the risks, however small, in our own business and in the wider supply chain.

This statement sets out Integreon’s actions to understand and address potential modern slavery risks related to its business and supply chain and to ensure it is doing all it can to prevent slavery and human trafficking.

Our business

Integreon is a trusted provider of integrated legal, research and business support solutions to discerning professionals, including law firms and corporate law departments, leading corporations, financial services organisations and professional services firms.

Our Supply Chains and Suppliers

Integreon’s existing relationships with its suppliers have been established for some time and are built upon mutually beneficial, collaborative business endeavors. To date, we have not been made aware of any human trafficking or slavery activities within our supply chain. However, if we were to learn of any such activities, Integreon would act immediately in accordance with our legal and moral obligations.

As and when Integreon has new contractors or suppliers come on-board, we pre-qualify any new firm through a series of due diligence efforts, including inquiry into company performance, Health Safety & Environment compliance, and references from other customers to establish reputation and suitability.

Due diligence processes for addressing and preventing slavery and human trafficking

In addition to our general due diligence processes for screening and monitoring suppliers, as part of our initiative to identify and mitigate risk around slavery and human trafficking, we have put in place (or are in the process of developing) systems to:

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery Policy is available at www.integreon.com. That policy prohibits the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children by any of our contractors, suppliers or other business partners. As such, it reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Training

We have zero tolerance for slavery and human trafficking. To maintain awareness and ensure a high level of understanding of the risks of modern slavery and human trafficking in our business our Anti-Slavery Policy is available at www.integreon.com. Integreon also provides training on its policy to those who are in positions where slavery and human trafficking concerns may arise.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Company’s slavery and human trafficking statement for the financial year ending 2019.

Anti-Slavery and Human Trafficking Policy

1. Policy Statement

1.1. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Integreon has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. In accordance with this commitment, Integreon employees, contractors, subcontractors, vendors, suppliers, partners and others through whom Integreon conducts business must not engage in any practice that constitutes trafficking in persons or slavery.

1.2. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labor, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

1.3. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

1.4. This policy does not form part of any employee's contract of employment and we may amend it at any time.

2. Responsibility for the Policy

2.1. The Management Team has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

2.2. The Chief Operations Officer has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

2.3. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

2.4. You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to info@integreon.com.

3. Compliance with the Policy

3.1. You must ensure that you read, understand and comply with this policy.

3.2. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

3.3. You must notify management as soon as possible if you believe or suspect that a violation of this policy has occurred, or may occur in the future.

3.4. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

3.5. If you believe or suspect a breach of this policy has occurred or that it may occur you must notify management or report it in accordance with our Code of Business Ethics and conduct Policy as soon as possible.

3.6. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with management.

3.7. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform management immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

4. Communication and Awareness of this Policy

4.1. Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

4.2. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

5. Breaches of this Policy

5.1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

5.2. We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.