Anti-Modern Slavery Policy

Anti-Modern Slavery & Human Trafficking Policy

Policy review date: March 2023

Modern slavery is a fundamental violation of basic human rights and a crime. It takes various forms including slavery, servitude, forced or compulsory labour and human trafficking. These offences are closely related but legally distinct:

• Slavery is where ownership is exercised over a person;
• Servitude involves the obligation to provide services imposed by coercion;
• Forced or compulsory labour involves work or service exacted from any person under the menace of a penalty and for which the person has not offered himself or herself voluntarily; and
• Human trafficking involves arranging or facilitating the travel of another with a view to exploiting them.

The Purpose of this Policy

The purpose of this policy is to establish Krome’s stance regarding Anti-Modern Slavery and Human Trafficking. Krome strictly prohibits the use of modern slavery and human trafficking in our operations, and reviews the commitment of our supply chain partners to preventing modern slavery and human trafficking within their business operations.

It is the responsibility of every Krome employee and third-party employee, with access to Krome systems and information resources, to ensure that they have read and understood this document. Anyone employed by Krome is obliged to adhere to these controls; failure to do so may result in disciplinary action and possible termination of employment.

Activities which affect Krome’s business interests, in or outside of work, including any information relating to Krome or Krome customers must not result in harm or damage to the company’s reputation and comply with:

• Krome’s values, operating principles and code of conduct
• Applicable laws, regulatory or legislative standards

Policy Statement

Krome is committed to taking steps to ensure that modern slavery is not taking place:

• In any part of its own business; and
• In any of its supply chains.

Krome expects all members of staff:

• To work with the Company as it takes these steps
• To remain vigilant in identifying circumstances where there is a risk that modern slavery might be occurring in any part of Krome’s business or in any of its supply chains
• To report any such circumstances to senior management in full and without delay
• To conduct their own personal and domestic affairs in such a way to ensure that they are in no way connected with modern slavery either through the commission of a criminal offence or through actions or omissions that might bring themselves and the Company into disrepute.

Policy Monitoring

Krome will from time to time assess and review the risk that modern slavery and human trafficking may be occurring in any part of its own business and in any of its supply chains. In light of any such risk assessments it may from time to time seek specific reassurances from its contractors, suppliers and other business partners; and seek to carry out due diligence or specific audits either itself or through third parties to satisfy itself that modern slavery is not occurring. In particular:

• That individuals working for the Company are made aware of this policy
• Ensuring the immediate and thorough assessment of any reported incident, and engaging the relevant authorities in its investigation

Monitoring the effectiveness of this policy is essential, in order to assess its efficiency in ensuring that Krome meets its obligations to prevent modern slavery and human trafficking within Krome, and Krome’s supply chains. Krome is committed to transparency in its approach to tackling modern slavery consistent with its disclosure obligations under section 54 of the Modern Slavery Act 2015.

Review and Amendments

This policy document forms part of the Krome Information Security Management System (ISMS) and is subject to Krome’s document and quality review standard. This document will be reviewed every 2 years, or in the event of:

•  New threats to systems or services
• Any security measure or incident that affects Krome’s systems or services
• Changes to industry good practice, regulatory or legislative standards