Anti Modern Slavery Policy

Last updated: December 1, 2024

1. Policy Statement

1.1. Modern slavery is a crime and a violation of fundamental human rights, which takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking. Belkins is committed to acting ethically and with integrity in all its business dealings, and we have a zero-tolerance policy toward modern slavery, human trafficking, forced labor, and other forms of exploitation within our business and supply chain.

1.2. The aim of this Policy is to ensure that Belkins, its affiliates, and their (sub)contractors act in accordance with the Modern Slavery Act 2015 and other applicable legislation related to the prohibition of modern slavery, maintain the best standards of business practice, and advise individuals of our 'zero-tolerance' towards modern slavery.

1.3. This policy applies to all persons engaged by us or acting on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

1.4. This policy does not form part of any employee’s contract of employment and we may amend it at any time.

1.5. Belkins is committed to publishing an annual Modern Slavery Statement, as required by the Modern Slavery Act 2015. This statement will provide transparency on the steps we have taken to identify and mitigate the risk of modern slavery and human trafficking in our business and supply chain.

2. Our Business & Supply Chains

2.1. Belkins is a US-based company specializing in lead generation & appointment setting services with focus on the USA and other highly developed economies with lower risks of modern slavery and human trafficking. Our supply chain mostly involves vendors and contractors who provide software, data management, and operational support services, which are also considered “low-risk” industries in terms of modern slavery and human trafficking.

2.2. Notwithstanding the low risks of modern slavery and human trafficking in our supply chain, Belkins still implements different policies and processes described below to minimize this risk in its own business and supply chains, as modern slavery will not be tolerated in any way.

3. Company’s Measures to Prevent Modern Slavery

3.1. To prevent modern slavery and human trafficking, we implement the following measures in our company:

Safe work environment: we engage people with different backgrounds and propose a work environment free of discrimination and any inappropriate behavior. Our Code of Conduct (including Company’s guiding principles) presented to team members during the onboarding period ensures that everyone is treated with respect and dignity.
Terms of engagement: we do not use forced/compulsory labor or other unsatisfactory treatment towards team members by ensuring that the overall terms of engagement are voluntary and are consistent with the laws where a person resides, the minimum age requirements are followed, and (sub)contractors also comply with these requirements.
Reporting concerns: employees, supplier and other stakeholders are encouraged to report any concerns or suspicions of slavery or human trafficking to Company’s HR and legal teams;
Internal Investigations: our HR & Legal teams are responsible for investigations for known or suspected instances of slavery and human trafficking, and recommendations are presented to Company’s C-level.
Due diligence of (sub)contractors and suppliers: we implement various procedures described in Section 4 below and aimed at the prevention of modern slavery and human trafficking within our supply chain.
Training and capacity building: our HR team ensures that everyone within our company is aware of Code of Conduct (including Company’s guiding principles related to creation of safe work environment) through organization of regular meetings with the company.
Publication of policy: we publish this Policy on our website to ensure that our partners are aware of these requirements and similarly follow the best standards of business practices.

3.2. Apart from the existing measures, we at Belkins regularly review and update our policies to adapt to new challenges and ensure compliance with up-to-date standards.

4. Due Diligence & Risk Management

4.1. In order to ensure the compliance of our (sub)contractors and suppliers with this policy, Belkins implements a range of due diligence procedures and preventive measures:

Contractual warranties: agreements with supplies include clauses ensuring compliance with all applicable laws, including prohibition of slavery and human trafficking.
Advice: Belkins may also take steps to improve suppliers’ practices by providing advice related to implementation of the best practices for prevention of modern slavery and human trafficking.
Sanctions: in case of breaching our policies with respect to modern slavery, we may invoke sanctions against suppliers that fail to improve their performance, inclduing by termination of agreement and indemnification of damages caused by non-compliance with the policies.
Audits: we conduct audits of new clients as well as period reviews of high-risk suppliers to ensure compliance with our standards;
Prioritization: Belkins prioritize working with credible and accredited suppliers that have clear & publicly available policies against modern slavery and human trafficking.

4.2. In the event of allegations or suspected instances of modern slavery and human trafficking, Belkins will:

Conduct a thorough investigation, led by our HR and Legal teams.
Notify the relevant authorities and regulatory bodies, as required by law.
Take immediate action to address the issue, including terminating agreements with suppliers or contractors found to be involved in modern slavery and human trafficking.
Provide support and protection to any individuals affected by modern slavery and human trafficking.
Review and revise our policies and procedures to prevent similar incidents from occurring in the future.
Report on the outcome of the investigation and any resulting actions in our annual Modern Slavery Statement.

5. Effectiveness & Performance Indicators

5.1. Belkins measures the effectiveness of our policies against modern slavery and human trafficking by monitoring the outcomes of supplier due diligence as well as analysis of the number of known or suspected cases of modern slavery and human trafficking in our business and supply chain.

5.2. We believe that Belkins’s policies are effective against modern slavery and human trafficking practices, which is also corroborated by numerous awards, including 2024 Gold Stevie Award in the Great Employers category. As of the effective date of this Зolicy, we are not aware of any cases or allegations of modern slavery or human trafficking against us or any of our current (sub)contractors and suppliers. If such allegations arise, we will immediately conduct an investigation and report this to the authorities where legally required.