This is Amber (Isle of Man) Limited's human trafficking and anti-slavery policy. This policy was last updated on 23rd April 2020.
1. What Does this Policy Cover?
This Human Traffic and Slavery Policy (this “Policy”) exists to set out the responsibilities of Amber (Isle of Man) Limited, its subsidiaries and all the employees of such entities (“Amber”, “us”, “we”, or “our”) with regard to observing and upholding our zero-tolerance position on human trafficking and slavery.
This policy also exists to act as a source of information and guidance for those working for Amber. It helps them recognise and deal with any human trafficking or slavery issues, as well as understand their responsibilities in this regard.
2. Policy Statement
Amber is committed to conducting its business in an ethical and honest manner and to implementing and enforcing systems that ensure human trafficking and slavery is prevented at all times. Modern slavery is a crime and a violation of fundamental human rights. We recognise that it can take 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 have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and strive to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere within our organisation.
We are also committed to ensuring that there is transparency in our business and that our approach is consistent with our disclosure obligations under all relevant applicable Modern Slavery laws. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
3. Who is covered by this Policy?
This Policy applies to all Amber employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third-parties), or any of our subsidiaries or their employees, no matter where they are located. This Policy also applies to our Officers, Trustees, Board, and/or Committee members at any level.
In the context of this Policy, ‘third-party’ refers to any individual or organisation we meet and work with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.
Any arrangements Amber makes with a third-party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to human trafficking and slavery.
4. Mitigating Actions
As part of our initiative to identify and mitigate the risk of human trafficking and slavery practices we have in systems in place to routinely:
Identify and assess potential risk areas in our business and supply chains;
Mitigate the risk of slavery and human trafficking occurring in our supply chains;
Monitor potential risk areas in our supply chains; and
Protect any employee or person reporting any suspicions or knowledge of instances of human trafficking or slavery.
5. Employee Responsibilities
As an employee of Amber, you must ensure that you read, understand, and comply with the information contained within this Policy, and with any training or other human trafficking and slavery information you are given.
All employees and those under our control are equally responsible for the prevention, detection, and reporting of any knowledge or suspicion of human trafficking or slavery. You are required to avoid any activities that could lead to, or imply, a breach of this Policy.
If you have reason to believe or suspect that an instance of human trafficking or slavery has occurred or will occur in the future that breaches this Policy, you must notify our Head of Compliance.
If any employee breaches this Policy, you will face disciplinary action and could face dismissal for gross misconduct.
6. What Happens if I need to raise a Concern?
How to raise a concern: If you suspect that there is an instance of human trafficking or slavery activities occurring in relation to Amber, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered human trafficking or slavery, you should speak to our Head of Compliance.
Employees should vocalise any concerns swiftly and confidentially.
Amber will ensure that no one suffers any detrimental treatment as a result of being subject to or reporting on any instances of human trafficking or slavery.
Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.
If you have reason to believe you’ve been subjected to unjust treatment as a result of or any connection to an instance of human trafficking or slavery, you should inform our Head of Compliance immediately.
7. Training and Communication
We will provide training on this Policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this Policy, and will be asked annually to formally accept that they will comply with this Policy.
This Policy and Amber’s zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.
Amber will provide relevant human trafficking and slavery training to employees etc. where we feel your knowledge of how to comply with the requirements in this area needs to be enhanced. As good practice, all businesses should provide their employees with human trafficking and slavery training where there is a potential risk of exposure to such matters during work activities.
8. Record Keeping
We will keep detailed and accurate records and will have appropriate internal controls in place to act as evidence for all reports made and actions taken.
9. Monitoring and Reviewing
Our compliance department is responsible for monitoring the effectiveness of this Policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.
Internal control systems and procedures designed to prevent human trafficking and slavery are subject to regular audits to ensure that they are effective in practice.
Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this Policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the Head of Compliance.