Anti-Slavery and Human Trafficking

AlphaTheta EMEA Limited (“ATE”) take seriously our responsibility in the protection of fundamental human rights and the elimination of modern slavery by ensuring that slavery, human trafficking and child labour has no place in our business or supply chain.

About this policy

This policy sets out the expected standards of conduct for all agents, intermediaries, consultants, contractors, suppliers, service providers, dealers, distributors, sub-contractors and any other third party who works for, or on behalf of, ATE anywhere in the world (“Business Partners”).

ATE does not tolerate any form of slavery and human trafficking and expects its Business Partners to adhere to the same standards. Failure to do so could result in the termination of business relationships and legal liability.

We recognise that market practice varies across the territories in which ATE does business and therefore what is normal and accepted in one place may not be accepted in another.  However, we are fully committed to complying with our obligations under all applicable legislation, including the Modern Slavery Act and the European Convention on Human Rights (“Anti-slavery and Human Trafficking Laws”), in ensuring the right to be free from forced labour, slavery and servitude, which is a human right under international law by anyone acting on behalf of ATE, anywhere in the world. 

Reporting concerns

We request that if any concerns arise, that such concerns are raised with us so that the matter can be dealt with appropriately.

If you are ever in doubt about a situation you find yourself in and are concerned about a possible breach of this policy or any other slavery and human trafficking connected with ATE, you must let us know by reporting to your contact at ATE and the ATE Company Secretary (details below).

What happens if you don’t comply?

We expect all our Business Partners to adopt high standards to prevent modern slavery, by ensuring all employees and workers are treated with dignity and respect in a fair and ethical environment.

We may audit key Business Partners on an ad hoc basis to ensure compliance. We expect our Business Partners to adopt the same principles when contracting with their own business partners and carry out the necessary checks required to remain compliant.

Business Partners may be required to complete a questionnaire to assist ATE to carry out an assessment and will be asked to contract on terms which ensure that we can check

Failure to comply with this policy may result in criminal prosecution under the relevant Anti-slavery and Human Trafficking Laws.  An offence under the Anti-slavery and Human Trafficking Laws can result in an unlimited fine and/or up to 10 years’ imprisonment.  Any breach of this policy may also lead to a termination of your business relationship with ATE.

Our expectations

ATE expects its Business Partners to conduct themselves with integrity, impartiality and honesty at all times when conducting business with, or on behalf of, ATE. 

Business Partners are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour.

 

In order to identify and mitigate potential modern slavery risks, we reserve the right to take the following approach to our Business Partners due diligence:

 

·      Audit of Business Partners

·      Review the information provided to verify Business Partners’ compliance

 

Queries/Contact: If you have any queries, relating to this Policy, please contact the Company Secretary at ATE:  

AlphaTheta EMEA Limited

Company Secretary

Artemis, Odyssey Business Park,

West End Road, South Ruislip,

Middlesex, HA4 6QE, UK

Telephone +44(0)203 761 7220

Email: Exec.eu@pioneerdj.com

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