Modern Slavery Policy

EITCA Academy Modern Slavery Due Diligence Policy

This document specifies the European IT Certification Institute’s Policy in regard to modern slavery due diligence. We do not tolerate any form of modern slavery, including forced labor, human trafficking, or child labor, in our organization or in our supply chain. We are committed to promoting ethical labor practices and conducting due diligence to identify and mitigate the risk of modern slavery in our operations and supply chain. We ensure that all our employees and suppliers are aware of our zero-tolerance against modern slavery and the actions we are taking to address this issue. All our operations are implemented ensuring ethical labor practices. This document is regularly reviewed and updated to ensure its effectiveness and relevance. The last update to the EITCI Modern Slavery Due Diligence Policy was made on 30th April 2022.

Part 1. Introductory Provisions

The European IT Certification Institute is committed to acting ethically and with integrity in all our operational dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own operations or in any of our supply chains. We recognize our responsibility to help eliminate modern slavery and human trafficking, and we are committed to complying with all relevant laws and regulations related to this issue.

This policy sets out our approach to ensuring that modern slavery is not taking place in any part of our operations or supply chains. This policy applies to all employees, contractors, suppliers, and any other parties who work on our behalf in any capacity, as well as any other parties with whom we have a operational relationship. This policy is regularly reviewed and updated to ensure its continued suitability and effectiveness.

Our commitment to preventing modern slavery is supported by the following principles:

1.1. Zero Tolerance to Modern Slavery

We have a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our operational dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own operations or in any of our supply chains.

1.2. Legal and Regulatory Compliance

We comply with all relevant legislation and regulations related to modern slavery and human trafficking. This includes the UK Modern Slavery Act 2015 and any similar laws in the countries where we operate.

1.3. Due Diligence

We conduct due diligence on our supply chains to identify and assess the risk of modern slavery and human trafficking. We work with our suppliers to ensure that they also have policies and procedures in place to prevent modern slavery.

1.4. Reporting

We encourage all employees and others who work on our behalf to report any concerns related to modern slavery and human trafficking. We have established appropriate channels for reporting such concerns, and we investigate and take appropriate action on all reports of suspected or actual modern slavery.

1.5. Training and Awareness

We provide training and awareness-raising to all employees and others who work on our behalf to ensure that they understand the risks and impacts of modern slavery and human trafficking and know how to identify and report any concerns related to these issues.

1.6. Continuous Improvement

We are committed to continuous improvement in our approach to preventing modern slavery and human trafficking. We regularly review and update our policies and procedures to ensure their continued suitability and effectiveness in preventing modern slavery.

Part 2. Governance

We are committed to ensuring that our operations and supply chain are free from modern slavery and human trafficking. To ensure compliance with this policy, we have established a governance framework consisting of the following components:

2.1. Responsibility

The Board of Directors of our company is ultimately responsible for ensuring that this policy is implemented and adhered to. The responsibility for implementing this policy and ensuring compliance with it at the operational level rests with our Executive Director. All employees, suppliers and our members are responsible for cooperating with implementation of this policy.

2.2. Training and Awareness

We provide training to our employees to help them understand the risks of modern slavery and human trafficking and how to identify and report any suspected instances of such practices. We also expect our suppliers to provide training to their employees on the risks of modern slavery and human trafficking and how to report any suspected instances of such practices.

2.3. Due Diligence

We conduct due diligence on our suppliers to ensure that they are not engaged in modern slavery or human trafficking practices. We conduct due diligence on new suppliers before engaging with them and regularly review the due diligence process for existing suppliers. We also expect our suppliers to conduct due diligence on their own suppliers to ensure that they are not engaged in modern slavery or human trafficking practices.

2.4. Risk Assessment

We conduct regular risk assessments to identify any areas in our operations and supply chain where there may be a risk of modern slavery or human trafficking. We use the findings of these assessments to inform our due diligence process and to take appropriate steps to mitigate any identified risks.

2.5. Reporting and Monitoring

We encourage our employees, suppliers, and other stakeholders to report any suspected instances of modern slavery or human trafficking. We have established a reporting mechanism that allows for confidential reporting and investigation of such reports. We also regularly monitor the implementation of this policy and review it to ensure its ongoing suitability, adequacy, and effectiveness.

Part 3. Risk Assessment

At the European IT Certification Institute, we recognize that the risk of modern slavery practices exists not only within our own operations but also within our supply chain. We are committed to identifying and assessing these risks on an ongoing basis through a comprehensive risk assessment process.

3.1. Risk Identification

We identify the risk of modern slavery practices through various means, including but not limited to:

  • Analyzing our operations and supply chain to identify any high-risk activities or geographies where modern slavery is prevalent.
  • Conducting due diligence on new suppliers and subcontractors to identify any potential risks related to modern slavery practices.
  • Regularly reviewing news sources and credible reports related to modern slavery practices to identify any new or emerging risks.

3.2. Risk Assessment

Once the risks have been identified, we assess their likelihood and potential impact on our operations and reputation. This includes considering factors such as:

  • The nature and size of the activity, product or service.
  • The country or region in which the activity, product or service is taking place.
  • The complexity and structure of the supply chain.
  • The reputation and track record of suppliers and subcontractors.

3.3. Risk Mitigation

We take a risk-based approach to mitigating the risks of modern slavery practices in our operations and supply chain. We prioritize our efforts based on the severity of the risk and our ability to influence it. Our risk mitigation strategies may include:

  • Engaging with suppliers and subcontractors to understand and address any identified risks related to modern slavery practices.
  • Conducting site visits and audits to assess the level of compliance with our modern slavery and due diligence policies.
  • Providing training to our employees, suppliers, and subcontractors on modern slavery and human rights.
  • Implementing contractual clauses with suppliers and subcontractors that require compliance with our modern slavery and due diligence policies.
  • Conducting ongoing monitoring and reporting of our supply chain to identify and address any potential risks related to modern slavery practices.

We are committed to continuous improvement and will review and update our risk assessment processes on an ongoing basis to ensure that we are effectively identifying and mitigating the risks of modern slavery practices within our operations and supply chain.

Part 4. Due Diligence

We recognize that at the core of our modern slavery policy is the relevant due diligence process, which involves various methods and types of information gathered and processed to ensure countering of any form of the modern slavery in our operations and supply chains.

4.1. Overview of Due Diligence Process

We recognize the importance of conducting due diligence to identify and assess potential modern slavery risks associated with our supply chain. Our due diligence process is designed to identify, prevent, mitigate, and remediate risks of modern slavery and human rights abuses within our supply chain. We use a risk-based approach to tailor our due diligence process to our suppliers and the countries they operate in. Our due diligence process includes but is not limited to:

  • Conducting risk assessments of suppliers based on factors such as country of origin, industry, and supplier history.
  • Expecting suppliers to complete self-assessment questionnaires to help identify potential modern slavery risks within their own supply chains.
  • Conducting supplier audits, including interviews with workers and management.
  • Reviewing supplier practices related to labor rights, human trafficking, and forced labor.
  • Monitoring supplier compliance through ongoing engagement and review.

4.2. Due Diligence Measures for High-Risk Industries and Geographic Locations

For suppliers in high-risk industries or geographic locations, we conduct additional due diligence measures, including but not limited to:

  • Conducting third-party background checks on suppliers and their principals.
  • Working with experts to assess risks associated with specific suppliers and countries.
  • Conducting unannounced inspections to assess working conditions and compliance with our ethical and social responsibility standards.

4.3. Decision-Making Based on Due Diligence Results

The results of our due diligence process inform our decision-making processes related to supplier selection, retention, and termination. If we identify modern slavery or human rights abuses within a supplier’s operations or supply chain, we take immediate action to address the issue. This may include:

  • Expecting suppliers to implement corrective actions to address identified risks.
  • Terminating relationships with suppliers that fail to meet our ethical and social responsibility standards.
  • Reporting identified issues to appropriate authorities and stakeholders as required by law or regulation.
  • We recognize that due diligence is an ongoing process and we continually evaluate and update our approach based on the evolving risks and regulatory environment.

4.4. Monitoring and Review

We regularly monitor and review our due diligence processes to ensure that they remain effective and relevant. We use metrics and indicators to measure the performance of our due diligence processes and identify opportunities for improvement. We also review our due diligence processes as part of our periodic management reviews to ensure their ongoing suitability, adequacy, and effectiveness.

Part 5. Supplier Engagement

We recognize that our suppliers and contractors play a important role in our efforts to prevent modern slavery and protect human rights. We are committed to working with suppliers who share our values and principles regarding modern slavery and ethical business practices.

5.1. Supplier Due Diligence

We are committed to conducting due diligence on our suppliers to ensure that they share our values and do not engage in modern slavery practices. We assess and monitor our suppliers based on their risk of modern slavery, taking into account factors such as country of operation, industry, and the nature of the goods or services provided. Our due diligence process includes:

  • Conducting a risk assessment of our supply chain to identify areas that are more vulnerable to modern slavery.
  • Evaluating our suppliers’ compliance with modern slavery laws and regulations.
  • Expecting suppliers to complete a modern slavery self-assessment questionnaire.
  • Conducting audits and inspections of suppliers’ facilities and operations to ensure compliance with our policies and standards.
  • We reserve the right to terminate contracts with suppliers who do not comply with our policies and standards on modern slavery and ethical operations practices.

5.2. Supplier Code of Conduct

We require all suppliers to adhere to our Supplier Code of Conduct, which includes a commitment to ethical and sustainable business practices and prohibits the use of forced labor and human trafficking and which outlines the standards and expectations we have for their conduct and business practices. We communicate our expectations to suppliers and regularly review their compliance. Our Supplier Code of Conduct includes provisions relating to modern slavery and human rights, such as:

  • Prohibition of any form of forced or compulsory labor.
  • Prohibition of any form of child labor.
  • Fair and ethical treatment of workers.
  • Compliance with all applicable laws and regulations regarding labor, health and safety, and the environment.
  • Protection of the environment and responsible use of natural resources.
  • We require all our suppliers and contractors to acknowledge and agree to our Supplier Code of Conduct as a condition of entering operational relations with us.

5.3. Supplier Assessment

We conduct a risk assessment of new and existing suppliers to determine the level of due diligence required. We use a risk-based approach to assess suppliers, taking into account factors such as country of operation, industry, and the nature of the goods or services provided.

5.4. Supplier Audits

We conduct audits of high-risk suppliers to verify their compliance with our Supplier Code of Conduct and identify any potential risks of modern slavery. We may use third-party auditors to conduct these audits.

5.5. Supplier Contracts

We include anti-modern slavery clauses in our supplier contracts, which require suppliers to comply with our Supplier Code of Conduct and any applicable laws and regulations related to modern slavery.

5.6. Supplier Monitoring

We monitor our suppliers and contractors on an ongoing basis to ensure compliance with our policies and standards. We use a variety of methods to monitor our suppliers, including:

  • Regular audits and inspections to assess compliance with our policies and standards.
  • Review of supplier performance metrics and key performance indicators.
  • Ongoing dialogue and engagement with suppliers to identify areas for improvement and to address any issues or concerns.
  • We take appropriate action to address any instances of non-compliance or potential violations of our policies and standards, which may include corrective action plans, termination of contracts, or other remedial measures as appropriate.

5.7. Supplier Training

We provide optional training and support to our suppliers and contractors on modern slavery and ethical business practices. We offer training and guidance on:

  • Identifying and preventing modern slavery in their operations and supply chains.
  • Adherence to our policy regarding modern slavery and ethical business practices.
  • Reporting and addressing any concerns or issues related to modern slavery and ethical business practices.
  • We encourage our suppliers and contractors to raise any concerns or issues related to modern slavery and ethical business practices and provide channels for them to do so in a confidential and secure manner.

Part 6. Employee Engagement

6.1. Employee Due Diligence

We are committed to ensuring that our employees are not at risk of being subjected to modern slavery practices. We conduct due diligence on our employees as part of our recruitment and onboarding process. Our due diligence process includes the following:

6.2. Recruitment

We verify identity of job candidates and conduct background checks to ensure that they have the right to work in the country and are not at risk of being subjected to modern slavery.

6.3. Employee Training

We provide training to our employees on modern slavery and human trafficking to increase awareness and understanding of these issues.

6.4. Grievance Mechanism

We have established a grievance mechanism that allows employees to report any concerns related to modern slavery or other unethical practices. We take all reports seriously and investigate them promptly and thoroughly.

6.5. Mergers and Acquisitions Due Diligence

We conduct due diligence on any potential mergers or acquisitions to identify any risks related to modern slavery practices. Our due diligence process includes a review of the target company’s policies, procedures, and practices related to modern slavery and human trafficking.

Part 7. Monitoring and Reporting

We understand that the key to the effective implementation of our Modern Slavery and Due Diligence Policy is ongoing monitoring and reporting. To achieve this, we have put in place a robust monitoring process that enables us to track progress, identify areas for improvement, and take corrective action where necessary.

7.1. Monitoring

Our monitoring process is designed to ensure that our policy is being effectively implemented and is achieving its intended outcomes. We monitor our supply chains and operations on an ongoing basis to ensure compliance with this policy and identify any potential risks of modern slavery. Our monitoring process includes:

  • Conducting regular audits and assessments of our suppliers and subcontractors to ensure they comply with our policy and relevant laws and regulations.
  • Reviewing supplier contracts and agreements to ensure they include provisions related to modern slavery and ethical sourcing practices.
  • Engaging with stakeholders and industry groups to stay informed about emerging issues and best practices related to modern slavery and ethical sourcing.
  • Conducting internal reviews and risk assessments to identify potential areas of exposure and opportunities for improvement.

7.2. Reporting

We are committed to transparency and accountability in our efforts to combat modern slavery.
To that end, we report on our progress and performance in several ways:

  • Making our policies and procedures related to modern slavery and ethical sourcing publicly available on our website.
  • Engaging with stakeholders, including investors, customers, and civil society organizations, to share information about our efforts to combat modern slavery and receive feedback.
  • Participating in relevant industry initiatives and collaborating with other stakeholders to address modern slavery risks and promote responsible sourcing practices.
  • We also encourage our suppliers and subcontractors, as well as employees to report any concerns or suspected cases of modern slavery to us through our grievance mechanisms. We take all reports seriously and investigate them promptly and thoroughly and report findings to relevant authorities.

We take all reports of suspected modern slavery seriously and investigate them promptly and thoroughly. Employees, suppliers, or other stakeholders who become aware of a suspected modern slavery incident are encouraged to report it immediately to our Board of Directors or to any member of management or HR by any communication means. All reports of suspected modern slavery will be investigated promptly and thoroughly, and appropriate action will be taken in accordance with our policy and relevant laws and regulations.

We are committed to promoting a culture of transparency, accountability, and ethical business practices, and we believe that our monitoring and reporting processes are critical to achieving this goal.

Part 8. Continuous Improvement

We are committed to continuously improving our efforts to prevent modern slavery and ensure responsible operational practices throughout our supply chains. Our approach to continuous improvement involves ongoing monitoring, evaluation, and review of our policies and procedures.

8.1. Regular Review

We conduct regular reviews of our Modern Slavery Due Diligence Policy and procedures to ensure that they are up to date and effective. We also review our relevant due diligence processes to identify areas for improvement and make changes where necessary.

8.2. Monitoring and Measuring

We continuously monitor and measure our performance against our objectives and targets in this polic to identify areas where we can improve. We use a range of metrics to track our progress and identify areas for improvement, including the number of suppliers audited, the number of suspected incidents reported, and the effectiveness of our training programmes.

8.3. Engagement and Collaboration

We engage with our suppliers and stakeholders to promote responsible business practices and identify opportunities for collaboration. We work with our suppliers to help them improve their practices and address any issues that are identified.

8.4. Training and Awareness

We provide training and awareness programmes to our employees and suppliers to ensure that they understand the risks of modern slavery and how to prevent it. We also provide guidance on how to identify and report suspected incidents of modern slavery.

8.5. Reporting

We regularly report on our progress to our stakeholders, including our employees, suppliers, customers, and members. We provide transparent and accurate information on our efforts to prevent modern slavery and promote responsible operational practices.

8.6. Third-party Verification

We may engage independent third parties to verify our compliance with this policy and our due diligence processes. This may include audits, assessments, and site visits to our suppliers and supply chain partners.

By continuously improving our policies, procedures, and processes, we aim to prevent modern slavery and ensure responsible operational practices throughout our supply chains. We are committed to being a responsible and ethical employment organization, and we will continue to work towards this goal through ongoing monitoring, evaluation, and review.