Anti-slavery and human trafficking policy
Policy statement
Modern slavery and human trafficking is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour 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. 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 and/or human trafficking is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery and human trafficking 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.
About this policy
The purpose of this policy is to:
- set out our responsibilities, and of those working for us and on our behalf, in observing and upholding our position on modern slavery and human trafficking; and
- provide information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
Responsibility for the policy
The leadership of Multiverse has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The General Counsel has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it.
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 and human trafficking in supply chains.
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 the general counsel. Please direct any such queries to legal@multiverse.io.
Your responsibilities and how to raise a concern
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery and human trafficking 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.
You must notify your manager as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery and/or human trafficking in any parts of our business or supply chains of any supplier at the earliest possible stage.
If you believe or suspect that a breach of this policy has occurred or that it may occur you must notify your manager as soon as possible.
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 and/or human trafficking, raise it with your manager immediately.
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 and/or human trafficking 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 unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should contact your manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our grievance procedure as outlined in the Grievance Policy.
Training and communication
Training on this policy, and on the risk our business faces from modern slavery and human trafficking 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.
Our commitment to addressing the issue of modern slavery and human trafficking in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them through use of our standard form questionnaire and reinforced as appropriate on an ongoing basis.
Breaches of this policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
Reviewed and updated:
February 2024