Stellar Omada Anti-Slavery and Human Trafficking Policy

Modern slavery is a crime and a violation of fundamental human rights.  All types of modern slavery have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Stellar Omada are committed to acting ethically and with integrity in all our business dealings and relationships and to ensure modern slavery is not taking place anywhere in our own business, or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our business relationships, consistent with our disclosure obligations under the Modern Slavery Act 2015.  Stellar Omada have a comprehensive on-boarding approach that evidences a persons right to work independently in the UK – this includes identity checks (e.g. Passport/Visa/Identity Card) along with detailed checks on employment history, basic disclosure, PEPS and sanctions checks.  Stellar Omada expect high standards from all of our subcontractors, suppliers and other business partners and will make this a contractual term in our agreements with significant suppliers wherever possible.  Periodically (annually) Stellar Omada undertaken a review of our supply chain to identify and assess potential risk areas and maintain a register detailing any concerns. 

Stellar Omada expect high standards from all of our subcontractors, suppliers and other business partners and have made this a contractual term in our agreements with significant suppliers wherever possible.

RESPONSIBILITY FOR THE POLICY

The senior management of Stellar Omada (ie any hiring manager) has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all of our people comply with it.

COMPLIANCE WITH THE POLICY

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

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 Stellar Omada or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Although you should report any concerns regarding modern slavery and/or human trafficking in any parts of our business or supply chains in accordance with our whistleblowing policy, you are also encouraged to discuss a specific matter (or our policy or relevant legislation) with any member of the legal department.

COMMUNICATION AND AWARENESS OF THIS POLICY

Our zero-tolerance approach to modern slavery is communicated to all significant suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

BREACHES OF THIS POLICY

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

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

Effective 3rd December 2020