Vertical Screen, Inc. Anti-Slavery Policy

1. Overview

Vertical Screen, Inc. (“Vertical Screen”) values human rights and is committed to ensuring that all business is conducted according to ethical, professional and legal standards in a fair, honest and open manner. It is vital for us to maintain this reputation as it generates confidence in our business.

Modern Slavery (as defined in Divisions 270 and 271 of the Criminal Code 1995 (Cth) (Modern Slavery) is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced labor, or trafficking. Additionally, the Modern Slavery Act of 2018 provides for additional instances of modern slavery such as child labor and debt bondage. This policy set forth below is pursuant to the United Kingdom (UK) Modern Slavery Act of 2015 and the Australian Modern Slavery Act of 2018.

2. Purpose

The purpose of this Anti-Slavery Policy (“Policy”) is to ensure Vertical Screen's compliance with obligations under the Modern Slavery Act. Such policy will reduce modern slavery risks posed to the business.

Vertical Screen has a zero-tolerance policy for Modern Slavery within all business operations and client relationships. We are committed to acting with the utmost ethics and integrity in all business interactions and we strive to ensure Modern Slavery does not take place within our workplace.

All Vertical Screen employees acknowledge receipt of a company Code of Conduct that provides similar expectations to ensure ethics in the workplace. This Policy is meant to expand on Vertical Screen policies and implement further standards to adhere to anti-slavery principles.

3. Scope

This Policy applies to all Vertical Screen directors, officers and employees. This Policy is meant to supplement our Code of Conduct and Business Ethics policy set forth in our Employee Handbook.

Vertical Screen requires strict compliance with the obligations set forth in this Policy. Modern Slavery can cause genuine and significant harm to the individuals affected and there are significant reputational, financial, market and operational risks if not properly detected and addressed.

This document sets out important information as to the steps Vertical Screen will take in response to identifying a Modern Slavery risk. The Policy will be reviewed and updated on an annual basis.

4. Ethical Standards Officer

Our Ethical Standards Officer is responsible for the administration and maintenance of this Policy. Our Ethical Standards Officer also has primary and day-to-day responsibility of implementing this Policy and for monitoring its use and effectiveness. Any questions regarding this Policy should be directed to the Ethical Standards Officer.

Vertical Screen's Ethical Standards Officer is Associate General Counsel, Ricki Abrams (rabrams@verticalscreen.com). 

The Ethical Standards Officer will report to Executive Management regarding the steps Vertical Screen has taken to ensure the Policy is not violated and that Modern Slavery does not take place within the workplace.

5. Confidentiality

All complaints will be kept confidential and will be dealt with appropriately. Any employee who believes that a breach of this Policy has occurred or is likely to occur, must notify their supervisor as well as the Vertical Screen Ethical Standards Officer. Employees will not experience any retribution or retaliation for a complaint made in good faith.

6. Policy Requirements

Vertical Screen employees, contractors, subcontractors, representatives, and agents must not engage in any practice that constitutes any form of Modern Slavery. This includes, but is not limited to, the following activities:

• Engaging in any form of trafficking in persons;
• Using forced labor in the performance of any work;
• Destroying, concealing, confiscating, or otherwise denying access by an individual to the individual’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority;
• Using misleading or fraudulent practices during the recruitment or offering of employment/contract positions to candidates. This may include: failing to disclose, in a format and language accessible to the potential candidate, basic information or making material misrepresentations during the recruitment of candidates regarding the key terms and conditions, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs, any significant cost to be charged to the candidate, and, if applicable, the hazardous nature of the work;
• Using recruiters that do not comply with local laws or charging applicants / candidates recruitment fees.
• If required by law or contract, failing to provide an employment offer, recruitment agreement, or other required work document in writing.

Some measures to ensure this Policy is being implemented may include

• Conduct of appropriate due diligence on business partners, agents, contractors, consultants, subcontractors and suppliers to ensure this Policy is not violated
• Training of all relevant individuals throughout Vertical Screen so that compliance with this Policy can be enforced and the principles set forth can be recognized. Such training may include: history of the problem, risk to our organization, how to identify signs of Modern Slavery, how to respond to Modern Slavery.
• Providing transparency in our business operations and in our approach to implementation of this policy
• Reviewing insight and guidance from various labor and human rights groups
• Sanctioning clients and or vendors who fail to meet our performance requirements

7. Investigation and Audits

Vertical Screen will perform routing audits, both internal and external, to verify that business is being conducted in compliance with this Policy.

Any failure by an employee to completely cooperate, or any action to hinder an investigation or audit, including for example, hiding or destroying any information or documentation, providing false answers or false information, or deleting emails or other documents, may be grounds for disciplinary action, up to and including termination, subject to applicable law.

8. Breach of this Policy

Any employee who breaches this Policy by engaging in or conspiring to engage in any Modern Slavery conduct will face disciplinary action. This could, in the most severe circumstances include immediate dismissal for misconduct or gross misconduct and, if warranted, legal proceedings may be brought against the employee.

The Ethical Standards Officer will arrange an investigation into reported breaches of this Policy. The outcome of the investigation included recommended actions will be reported to the Executive Leadership Team.

9. Key Contacts

If you have any questions about this policy, please contact the Ethical Standards Officer, Ricki Abrams (rabrams@verticalscreen.com) or General Counsel, Alex Erlam (aerlam@verticalscreen.com).