Anti-Slavery Policy

ComSim Inc. reaffirms its commitment to abjure and discourage any form of slavery and forced servitude or employment throughout its business operations and its value chain networks.

Comsim Inc. is not in an industry with a high risk of modern-day slavery, a risk-based approach has been adopted to review supply chains that fall within industries with a higher risk of this.

Risk Assessments

Risk assessments are carried out on our suppliers and sub-contracts by our procurement function. We do not usually sub-contract assignments to any third parties or agencies. Our most important suppliers are state governed utilities (Electricity and Gas, Telephone and Internet). As we are not in an industry with a high risk of modern-day slavery, a risk-based approach has been adopted to review supply chains that fall within industries with a higher risk of this.

Training

Relevant training is provided to employees (specifically those involved in procurement functions) in identifying the signs of modern slavery and implementing measures to prevent or minimize the risk of modern-day slavery in our business and supply chains as appropriate.

Employment

Only reputable employment or recruitment agencies will be used to source agency workers.

Identity Checks

Appropriate identity checks will be carried out to ensure that all new employees are eligible for work with ComSim.

Checks for recruiting new team members

• Legal documents – is the person in possession of identity documents (passport) and their own bank account?
• Right to work – is the person legally able to work in the country where they are hired?
• Appearance – do they appear unkempt or only have very few possessions?
• Behaviour – do they appear to be under the control or influence of others? Are they inconsistent with basic information such as address?
• Fear of authorities – are they nervous at the mention of the tax office or immigration?

When doing business with new clients and service providers, we conduct background checks and enquiries to understand how they deliver their services. Processes within our business development teams have been designed to help us notice signs of concern early on.

Think – are there any unusual signs in how the business provides its services?

• Unusual behaviour in meetings/offices
• Reluctance to share information that wouldn’t be an issue under normal circumstances
• Are there under age children in the office
• Signs of forced labour

We communicate a zero-tolerance policy in regards to modern slaver to all suppliers, contractors, and business partners at the outset of our business relationship. This is reinforced as appropriate.

Breach of this policy could result in disciplinary and further consequences

Any employee in breach of this policy will face disciplinary action which could result in dismissal for misconduct or gross misconduct.

We may also terminate any relationship with individuals and organizations working on our behalf if they are in breach of this policy

Any staff member with any concerns regarding modern day slaver can notify the HR team or a whistle-blowing officer to take necessary actions.

This policy enshrines the principles and practices that we shall apply at all times in the conduct of our business.