Modern slavery statement for 1 February 2023 to 31 January 2024
This statement sets out the steps that Mitratech Holdings, Inc. (“Mitratech”) has taken and is continuing to take to ensure that modern slavery and human trafficking is not taking place within our business or supply chain. This statement relates to the period 1 February 2023 to 31 January 2024.
Mitratech对任何形式的现代奴隶制，包括奴役、人口贩运和强迫劳动，都采取零容忍的态度。我们致力于在所有商业交易中以道德、诚信和透明的方式行事，并建立有效的制度和控制，以防止我们的业务和供应链中出现现代奴隶制。
我们的业务
This statement covers the activities of Mitratech and its subsidiary companies (as defined under the Companies Act 2006):
- Mitratech致力于解决法律和合规专业人士的复杂需求。
- Mitratech在美国、英国、印度和澳大利亚设有办事处，我们的大部分业务在美国境内进行。我们的承包商和供应商主要在美国和英国境内。
- 产品、服务和软件开发一般由Mitratech内部提供，而不是由第三方提供。
风险评估
Mitratech maintains on-going due-diligence of its material suppliers to assess whether any particular risks of slavery or human trafficking within its supply chains or any part of our business. We have zero tolerance to slavery and human trafficking. We evaluate our relationships with professional or business services suppliers, such as those who provide hosting support services to identify any potential risks. In part, we manage this risk through the use of suppliers whom are considered to be reputable, and we have specifically requested all material regular suppliers to confirm that their own business activities and supply chain do not involve slavery or human trafficking.
我们的政策
We have in place systems to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers.
We also operate a number of internal policies to ensure we conduct business in an ethical and transparent manner. We continuously review and update all our policies. These include:
- Corporate Social Responsibility Policy. This policy set out our commitment to promoting equal human rights for all, as well as monitoring the social, economic, and environmental impacts of our business.
- Anti-Bribery and Corruption Policy. This policy underpins our commitment to maintaining high standards of ethics, morality and legality in all areas where our business is carried out.
- 招聘政策。我们对所有员工进行在英国工作的资格检查，以防止人口贩运或个人被迫违背其意愿工作。
- 揭发政策。我们实行举报政策，以便所有员工可以在不担心报复的情况下，对我们业务或供应链中的不当行为和做法提出关切。
- 员工手册。该手册解释了我们的行为准则；我们作为一个组织的行为方式以及我们期望我们的员工和供应商如何行事。
我们的绩效指标
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain (i) by monitoring how we and our suppliers perform against our standards and policies and (ii) if no reports are received from employees, suppliers, the public or law enforcement agencies to indicate that modern slavery practices have been identified. In the prior year, we have not been made aware of through our due diligence and have received no reports from employees, suppliers, the public or law enforcement agencies of alleged modern slavery practices within our business or supply chain.
Steps Mitratech will take in 2023
(A) 持续的管理责任和一般意识
- 向执行管理团队和董事会报告进展情况。
- 向经常与之打交道的供应商提高对这一公布的声明的认识。
- Determine if a modern slavery questionnaire to be completed by our key suppliers should be implemented within our supplier due diligence.
- Develop framework to ensure consistent standards and effectiveness across our business.
(B) 风险评估
- Re-evaluating the risk of non-compliance as part of our cyclical compliance risk register assessment:
- 在发现或标记出合规违规行为时及时采取行动。
- Re-evaluate appropriate processes for remediation of risks identified within our business or within our supply chain.
- 继续将学到的经验反馈到我们的合规风险管理过程中。
(C) 减少风险
- Improve upon our training. Provide additional training opportunities to our employees on identifying and addressing modern slavery awareness. Ensure our suppliers and business partners provide training to their employees and suppliers and providers.
- Taking steps to ensure our contracts require our suppliers adhere to our relevant policies or adhere to equivalent policies.
董事会批准
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Mitratech’s statement for the period 1 February 2023 to 31 January 2024.
This statement has been approved by Mitratech Holdings, Inc.’s board of directors, who will review and update it annually..
迈克-威廉姆斯
首席执行官
9 March 2023
