Appnovation Technologies, Inc.
Modern Slavery and Human Trafficking Statement
This Modern Slavery and Human Trafficking Statement is made on behalf of Appnovation Technologies Inc. and each of its subsidiaries (together "Appnovation") and relates to actions and activities during the financial year 1 September 2019 to 31 August 2020.
The statement sets down Appnovation’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.
Organisational structure and supply chains
Appnovation is a global full-service digital consultancy. We help businesses advance and inspire, create positive transformation, and champion digital innovation. Appnovation seamlessly integrates strategy, user experience, development, deployment, training, and support. Since its inception in 2007, Appnovation has amassed hundreds of clients, delivered thousands of digital projects and been internationally recognized for its development, innovations, and business success; winning dozens of awards to date. Appnovation has operations in Canada, United States, United Kingdom, Belgium, Netherlands, and Hong Kong. Appnovation’s own business operations and supply chain consists primarily of office-based professionals, with limited exposure to the risk of modern slavery.
The principal areas of risk we face, related to slavery and human trafficking, include:
- Temporary staff contracted through agencies
- Certain outsourced services
In this respect the risk arises from the fact that Appnovation does not control the engagement and treatment of individuals undertaking work. To manage these risk areas we have established certain processes and procedures. In that respect:
- Policies: Appnovation's Director, People & Culture is responsible for creating and reviewing policies, looking at best practice and adapting to Appnovation's needs. In that respect Appnovation has established a number of policies (detailed below) to assist in mitigating against the risk posed.
- Risk assessments: EVP, Global People & Operations is responsible for risk assessments in respect of human rights and modern slavery. The process includes evaluating the nature and extent of the risk of modern slavery and human trafficking within our business and supply chain, bearing in mind particularly the industries and geographies in which we operate.
- Due diligence: The Global Operations team is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking. Further detail of what this entails is set out below.
Appnovation requires all staff members who are involved in managing recruitment and/or vendors to undergo mandatory training to identify and understand the risks of modern slavery and human trafficking in our supply chains and business.
Appnovation is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships. The following internal policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
- Anti-Slavery and Human Trafficking Policy - Appnovation has implemented this policy as part of its commitment to a zero-tolerance approach to any form of modern slavery. It includes our commitment to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain. It encourages all those working with us to prevent, detect and report modern slavery if it is encountered.
- Whistleblowing/Disclosure Protection policy - Appnovation encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains. This policy can be used in the event that any relevant party has any concerns about the practices of any business or person within our supply chain.
- Business Ethics and Code of Conduct – this policy sets down the actions and behaviour expected of Appnovation's directors, officers and employees, including compliance with laws, integrity in business dealings, and compliance with anti-bribery legislation. It stresses the importance of adherence to high ethical standards and makes clear that strict adherence to the policy is an essential condition of employment.
Due Diligence Processes for Slavery and Human Trafficking
Appnovation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Appnovation's due diligence process includes:
- “Know Your Vendor”: knowing who is providing the services to us; supplier identity, level of risk, and adherence to anti-slavery measures in their businesses. All of this helps us to assess risk and determine whether we are satisfied that vendors have appropriate processes and safeguards in place to mitigate against any risks identified.
- Recruitment Processes:
- Conducting eligibility to work checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
- Providing information to all new employees on their statutory rights including sick pay, holiday pay, and any other benefits they may be entitled to.
- Only engaging with specified reputable recruitment agencies.
- Invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.
Performance indicators and future action
We will know the effectiveness of the steps that we are taking to prevent slavery and/or human trafficking if no reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
Over the next financial year we will be looking to enhance existing commitments in our standard terms of engagement with vendors to expressly require compliance with the Modern Slavery Act as an integral part of the contractual relationship.
This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Executive Team endorses this policy statement and is fully committed to its implementation.
This Modern Slavery and Human Trafficking Statement has been approved and authorised by:
Name: Arnold Leung
Date: September 11, 2020