Modern Slavery Policy Document

1. Introduction

Net1on1 Wholesale Ltd is committed to ensuring that modern slavery and human trafficking are not taking place in any part of our business or supply chains. This document outlines our policy and the measures we have put in place to mitigate the risk of modern slavery within our operations.

2. Scope

This policy applies to all employees, suppliers, contractors, and other business partners of Net1on1 Wholesale Ltd.

3. Definitions

– Modern Slavery: Encompasses slavery, servitude, forced and compulsory labour, and human trafficking.
– Human Trafficking: The recruitment, transportation, transfer, harbouring, or receipt of persons by improper means for an improper purpose including forced labour or sexual exploitation.

4. Commitment

Net1on1 Wholesale Ltd is committed to:
– Acting ethically and with integrity in all our business dealings and relationships.
– 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.
– Ensuring transparency in our own business and in our approach to tackling modern slavery throughout our supply chains.

5. Value Chain an Overview

1. Goods and Services Procurement

– Conduct risk assessments of suppliers.
– Engage with suppliers to ensure they adhere to our anti-slavery policies.
– Include anti-slavery clauses in all supplier contracts.

2. Own Brand Products

– Ensure all manufacturing partners comply with local and international labour laws.
– Conduct regular audits of production facilities.
– Provide training and resources to partners on ethical labour practices.

3. Logistics

– Work with logistics partners who share our commitment to ethical labour practices.
– Monitor and audit logistics partners regularly.
– Ensure fair wages and safe working conditions for all logistics workers.

6. Due Diligence Processes

To identify and mitigate the risk of modern slavery, we:

– Perform thorough due diligence checks on new suppliers and partners.
– Require all suppliers to complete a self-assessment questionnaire covering their labour practices.
– Provide training to employees on recognizing and addressing modern slavery.

7. Training and Awareness

– Provide training for all employees on modern slavery, including how to identify and report concerns.
– Ensure that management receives additional training on implementing and enforcing our anti-slavery policies.

8. Reporting Mechanisms

– Establish a confidential reporting system for employees and partners to report any suspicions of modern slavery.
– Investigate all reports thoroughly and take appropriate action.

9. Performance Indicators

To measure the effectiveness of our anti-slavery efforts, we will:
– Track the number of audits conducted and the outcomes.
– Monitor the number of modern slavery training sessions held.
– Record and follow up on any reported incidents of modern slavery.

10. Continuous Improvement

We are committed to continuously improving our policies and practices by:

– Regularly reviewing and updating our anti-slavery policy.
– Engaging with industry experts and stakeholders to stay informed of best practices.
– Encouraging feedback from employees, suppliers, and partners on our approach to combating modern slavery.

11. Statement of Approval

This policy has been approved by the Board of Directors of Net1on1 Wholesale Ltd.

By adhering to this policy, Net1on1 Wholesale Ltd aims to contribute to the global fight against modern slavery and ensure that our business operations and supply chains are free from forced labour and human trafficking.