Modern Slavery & Human Trafficking Policy

1. Policy Overview

Enlighta Inc. (“Enlighta”) is a global Software-as-a-Service (SaaS) provider headquartered in San Ramon, CA. Enlighta Inc. specializes in providing hosted supplier governance and service management software solutions to clients.

The purpose of this policy is to establish controls to ensure compliance with all applicable modern slavery & human trafficking regulations, and to ensure that the Company’s business is conducted in a socially responsible manner.

Enlighta has zero tolerance for slavery and human trafficking in any part of our business, including our supply chains. We have a number of policies in place to ensure all our employees have the right to work and are paid fairly, that we act with integrity and ethics, and that we have effective measures in place to ensure slavery is not present anywhere in our business or supply chain.

This includes our Equal Opportunities policy, which encompasses recruitment, promotion, training, performance management, and reward. Our principles of fair treatment and respect are also applied to our relationships with customers, suppliers, contractors, shareholders, and other stakeholders.

2. Scope

In this policy, the third party means any individual or organization Enlighta personnel come into contact with during the course of your work for us and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term, or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy). 

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

3. Objectives

Enlighta has implemented this Modern Slavery & Human Trafficking Policy to address the following objectives:

• Ensure that employees and contractors are required to follow the law, regulations, and internal policies with respect to ethical and lawful conduct with respect to modern slavery and human trafficking.
• Ensure that employees and contractors are aware of their responsibilities in relation to modern slavery, and governed by the same in their employment and consulting agreements. 
• Ensure the development of a strategic approach to identifying and tackling any modern slavery within our supply chains.
• Ensure the implementation of robust, transparent, and proportionate governance and assurance processes.
• Ensure employees and contractors can report instances (or concerns) of modern slavery in a safe and protected manner.

4. Roles and Responsibilities

• Executives – Ensure that the Modern Slavery & Human Trafficking Policy is established, periodically reviewed, and communicated to employees and contractors.
• Human Resources – Ensure that the key provisions of this policy are incorporated into employment and consultant agreements as required by the program. Establish a cadence of communication of policy review by employees and contractors.
• Management at all levels is responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.
• 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 Enlighta Executives and emailed to compliance@enlighta.com.

5. Policy

5.1 Policy Statement

5.1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor, 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. Enlighta is 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 is not taking place anywhere in our own business or in any of our supply chains.

5.1.2 Enlighta is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery 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, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or trafficked labor, 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.

5.2 Compliance with the policy

5.2.1 You must ensure that you read, understand, and comply with this policy.

5.2.2 The prevention, detection, and reporting of modern slavery 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.

5.2.3 You must notify HR as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

5.2.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains of any supplier tier at the earliest possible stage.

5.2.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your Manager OR Enlighta Executives or send an email to compliance@enlighta.com as soon as possible.

5.2.6 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, raise it with your Manager OR Enlighta Executives or send an email to compliance@enlighta.com as soon as possible.

5.2.7 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 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 unfavorable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your Manager OR Enlighta Executives or send an email to compliance@enlighta.com immediately. 

5.3 Communication and awareness of this policy

5.3.1 Training on this policy, and on the risk our business faces from modern slavery 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.

5.3.2 Our commitment to addressing the issue of modern slavery 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 and reinforced as appropriate thereafter.

5.4 Breaches of this policy

5.4.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

5.4.2 We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.

Note: This policy may be amended at any time.