Modern Slavery, Forced Labour & Human Trafficking Policy

1. Policy Statement

ABC Tech Ltd is committed to conducting business ethically and with integrity in all operations and supply chains. We have a zero-tolerance approach to modern slavery, forced labour, bonded labour, child labour, and human trafficking.

As a distributor of electronic components, technology products, and related services, we recognise the increased supply-chain risks associated with global manufacturing, logistics, raw material sourcing, and subcontracted labour. We are committed to complying with all applicable modern slavery and human trafficking legislation in the jurisdictions in which we operate and supply products and services.

This policy applies to employees, directors, contractors, temporary workers, suppliers, manufacturers, logistics providers, agents and intermediaries, and any third parties acting on behalf of the organisation.

2. Objectives

The organisation aims to:

• Prevent modern slavery and forced labour within its operations and supply chain
• Conduct business in accordance with ethical sourcing principles
• Assess and manage supply-chain risks
• Ensure suppliers comply with applicable labour and human rights laws
• Promote transparency and accountability throughout procurement and distribution activities
• Respond appropriately to identified risks or violations

3. Definitions

Modern slavery includes forced or compulsory labour; human trafficking; bonded labour; child labour; slavery or servitude; exploitative recruitment practices; withholding of identity documents or wages; and unsafe or coercive working conditions.

4. Responsibilities

Senior Management

Senior management is responsible for approving this policy, ensuring adequate resources and oversight, and monitoring compliance and effectiveness.

Procurement and Supply Chain Teams

Responsible for conducting supplier due diligence, assessing supplier risks, maintaining supplier compliance records, and escalating concerns.

Employees

Employees must comply with this policy, report suspected violations, and participate in training where required.

5. Supplier Standards

Suppliers and business partners are expected to:

• Comply with all applicable labour, employment, and anti-slavery laws
• Prohibit forced, involuntary, or trafficked labour
• Prohibit child labour
• Provide safe working conditions
• Pay lawful wages and benefits
• Allow employees freedom of movement and employment termination
• Maintain transparent recruitment practices
• Permit reasonable compliance assessments upon request

Suppliers must also ensure these standards are implemented within their own supply chains.

6. Due Diligence Processes

Supplier Onboarding

New suppliers are subject to supplier risk assessment, sanctions and compliance screening, review of ethical sourcing policies, acceptance of the supplier code of conduct, and assessment of country and industry risk factors.

Risk-Based Assessment

Higher-risk suppliers may require additional questionnaires, evidence of labour standards, third-party audit reports, and corrective action plans. Risk indicators may include manufacturing in high-risk jurisdictions, labour-intensive manufacturing, use of temporary or migrant labour, and lack of transparency within the supply chain.

Ongoing Monitoring

The organisation may periodically review supplier compliance, conduct supplier reassessments, request updated certifications or declarations, and monitor adverse media or regulatory findings.

7. Reporting Concerns

Employees, suppliers, and third parties are encouraged to report concerns relating to forced labour, human trafficking, exploitative employment practices, unsafe working conditions, and supplier misconduct. Reports may be made confidentially through line management, the HR department, a compliance contact, or whistleblowing procedures. Retaliation against individuals raising concerns in good faith is prohibited.

8. Non-Compliance

Where violations are identified, the organisation may require corrective actions, suspend procurement activities, terminate supplier relationships, and report serious matters to relevant authorities where appropriate.

9. Training and Awareness

Relevant employees involved in procurement, supplier management, logistics, and compliance may receive training on modern slavery indicators, supply-chain risk awareness, ethical sourcing obligations, and reporting procedures.

10. Policy Review

This policy will be reviewed periodically and updated as necessary to reflect legislative changes, supply-chain risks, industry best practice, and organisational changes.

Supplier Due Diligence Process

Step 1 — Supplier Identification: collect company registration information, identify manufacturing locations, determine source countries, and identify subcontracting arrangements.

Step 2 — Risk Classification: suppliers are categorised as low, medium, or high risk based on country risk, product category, labour intensity, and historical compliance concerns.

Step 3 — Compliance Documentation: obtain supplier code acceptance, ethical labour statements, ESG or sustainability policies, and audit certifications where applicable.

Step 4 — Review and Approval: procurement and compliance teams review documentation completeness, risk indicators, and corrective actions if required.

Step 5 — Ongoing Monitoring: annual supplier review, random compliance checks, incident monitoring, and escalation of concerns.

Supplier Code of Conduct (Summary)

Suppliers must prohibit forced labour and trafficking; prohibit child labour; provide fair wages and working hours; maintain safe workplaces; prevent discrimination and harassment; comply with environmental and legal obligations; maintain accurate records; and cooperate with compliance reviews.

Compliance Statement

“ABC Tech Ltd maintains policies and due diligence procedures designed to identify and mitigate risks of modern slavery and human trafficking within its operations and supply chain. Suppliers are expected to comply with applicable labour and ethical sourcing standards, and risk-based assessments are conducted as part of our supplier onboarding and monitoring processes.”