Verbatim Modern Slavery Act Transparency Statement

Introduction

Here at Verbatim, we are committed to respecting human rights and strive to ensure that all business activities do not cause or contribute to adverse human rights impacts. We are totally opposed to slavery and human trafficking in all aspects of our global operations, including our supply chain, and have a zero-tolerance to slavery and human trafficking.

Our Supply Chain

Our supply chain is sourced from countries all over the world. Due to this, we have a careful vetting process to ensure that our suppliers are aligned with our Corporate Charter of Behaviour and follow all legal and contractual obligations. Our charter covers our expectations in regards to topics such as employment and labour, health and safety, compliance, fair business practices, and information management. To assist with this vetting, we have a Code of Conduct for Business Partners which contains specific references to slavery and human trafficking.

While our operations and supply chains are complex, we aim to ensure that human rights issues are understood, respected, and upheld. We expect our business partners to adhere to ethical business conduct consistent with our own, and are committed to working with them to fulfil this common goal, and proactively address human rights. Our approach to doing this is anchored in our Responsible Sourcing Standards and Policy.

Our Policy and Standards

The Responsible Sourcing Policy outlines our commitment to upholding the human rights of the workers in our supply chain. The Policy applies to all of our suppliers globally and is a part of doing business with Verbatim.

The Responsible Sourcing Standards are a key way that we implement the Policy commitments. They include comprehensive criteria on business integrity, labour rights, fair and safe working conditions, and environmental compliance:

Compliance with Local Laws: Suppliers must comply with all relevant local laws, rules, and regulations in the countries where they operate, including those relating to business integrity, transparency, bribery, and corruption.

Management Systems: We believe that robust management systems, including hiring, disciplinary, and termination practices, are important for suppliers to build and develop in order to support compliance requirements and sustainability goals.

Social and Labour Standards: All workers must be treated with respect and dignity. Suppliers are to provide workers with a safe place to work, and respect workers’ rights to freedom of association. Workers’ grievances are to be heard, appropriately investigated, and any required remedial action taken, in addition to building capacity and awareness around social and labour practices.

Environmental Standards: Suppliers must comply with all applicable environmental laws and regulations, and maintain an environmental management system that identifies and manages environmental impacts.

We are committed to supporting suppliers with relevant information sessions, guidance documents, training materials, and, in higher-risk categories, establishing communities of practice.

In our Responsible Sourcing Standards, we commit to an annual review so we can ensure we maintain the right standards as against our standards and the expectations of our communities and customers.

Our review includes further detail regarding our verification and audit framework, clarification on the role of our guidance notes, and recognition of our extended Whistleblower program for management of grievances.

We recognise that many of our suppliers are already a part of a social compliance audit program. As such, we will now accept compliance information from different third-party schemes. These schemes were selected based on their coverage, governance, relevance to our at-risk supply chain and alignment to our Standards. The schemes are:

• amfori BSCI
• Supplier Ethical Data Exchange (Sedex) and SMETA
• Social Accountability (SA) 8000

Effective Grievance Mechanisms and Access to Remedy

Verbatim is committed to ensuring channels are provided through which adversely affected people or communities can raise complaints or concerns without fear of retaliation, intimidation, harassment, discrimination, or victimisation. This commitment extends to the work of human rights defenders, and the expectation they can operate in a safe and respectful environment across our operations.

With suppliers spread across so many countries, we acknowledge there are different socio-cultural barriers that may prevent vulnerable workers from raising concerns directly with their employer (our supplier). We are working to raise supplier awareness of the eight characteristics of an effective grievance process outlined by the United Nations Guiding Principles on Business and Human Rights (know as the UNGPs).

It is important to us that effective remedies are available for affected people and communities where it is identified that our operations have caused or contributed to adverse impacts. These remedies may be provided through direct engagement with affected people and communities, or in collaboration with our suppliers or other third parties.