Modern Slavery Statement

PURPOSE AND KEY PRINCIPLES

Modern Slavery and Human Trafficking legislation responds to the exploitation of workers in modern supply chains. Laws including the UK Modern Slavery Act, Modern Slavery Act 2018 Australia, and California Transparency in Supply Chains Act of 2010 (the “Legislation”) impose transparency and risk mitigation obligations on companies with the aim of ensuring the ethical treatment of workers.
Modern slavery can occur in various forms, including servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Cora Systems has adopted this policy with the aim of preventing opportunities for modern slavery occurring within its business and supply chains. In this policy, the term ‘modern slavery’ has the meaning given to that term in the Legislation. This policy applies all Cora Systems employees and contractors.

POLICY STATEMENT

Cora Systems has a zero-tolerance approach to modern slavery. We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business and in so far as is possible to requiring our suppliers hold a similar ethos. We are committed to acting ethically and with integrity in all our business dealings and relations and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains.

PREVENTION OF MODERN SLAVERY

In order to prevent the occurrence of incidents of modern slavery within our own business and throughout our supply chain we shall:
• identify, monitor and assess those areas of our business and supply chain most at risk from modern slavery
• engage with our contractors, suppliers and other business partners at the outset of our business relationship to convey to them this policy
• incorporate anti-slavery and human trafficking obligations as part of our procurement agreements and contractual processes and, where appropriate, carry out an audit and/or investigation of the activities of those contractors, suppliers or business partners deemed high risk; and
• provide training to relevant employees to facilitate achievement of the objectives of this policy.
• Recruiters shall not be used for hiring unskilled or entry level employees.
• In no event will recruitment fees be charged to employees.
• Wages should in all cases meet applicable legal requirements. Any concern as to this point should be directed to the Human Resources Department who shall ensure compliance in cooperation with Cora’s external employment law advisors.
• Although Cora does not routinely relocate employees, in the event there are specific circumstances requiring an employee who is not a national in their place of employment be brought into that country for the purposes of working, Cora will fund that employee’s return transportation at the end of their employment.
Although Cora does not routinely arrange housing for employees, in the event there are specific circumstances under which Cora does provide housing, such housing will meet any applicable housing and safety standards.
• Cora will always provide a written contract to employees and will ensure such contracts are provided to the employee prior to any company-required travel or relocation. Where required by law, contracts will be provided in the employee’s native language.

ROLES AND RESPONSIBILITIES

Cora Systems Management has overall responsibility for this policy. The key roles and responsibilities across Cora Systems in relation to this policy are as follows:

Management:
• day-to-day operational responsibility for the implementation of this policy
• allotting adequate and appropriate resources to ensure compliance with this policy
• ensuring managers and employees who may deal with concerns or investigations under this policy receive appropriate training
• promoting appropriate mechanisms to highlight modern slavery to help prevent it occurring in the recruitment, selection and employment of employees or other persons engaged via agencies to provide services for Cora Systems.

Employees (and third parties working for Cora System)
• attending trainings so as to be alert and aware to any signs of modern slavery or human trafficking
• engaging in business in such a way so as to help prevent the opportunity for any incidence of modern slavery occurring
• report any suspected incidents of modern slavery to management

REPORTING INCIDENTS

Employees
• Employees are encouraged in the first instance to report any wrongdoing to their line manager, as they would any other concern in the course of their duties. Should an employee not feel comfortable to discuss their concerns with their line manager they can speak to another member of our Senior Leadership Team, Our CEO or Head of HR.

Non-employees
• If contractors, external consultants, agents, third-party representatives, business partners working with us, or generally members of the public, have any concern, issue or suspicion of modern slavery in our business or related supply chain they can contact a member of Cora Systems Leadership by calling 1800 940 940 or write disclosing full details to Mercantile Plaza, 7 Bridge Street, Townparks, Carrick-On-Shannon, Co. Leitrim.

POLICY VIOLATION

An employee or contractor involved in a wrongdoing and/or in breach of this policy may face the following consequences:
• Individuals are advised that conduct amounting to an offence under applicable legislation can attract serious criminal penalties including incarceration.
Any matter which could be constituted as wrongdoing by an employee under this policy could be subject disciplinary action which could result in penalties up to and including dismissal.
• Any matter which could be constituted as wrongdoing by a contractor will be reported to the relevant person’s employer and may result in the termination of the service contract with the contractor and/or contracting company. Cora Systems may take action to recover any losses sustained, which may include the issuing of civil and/or criminal proceedings against the employee / contractor and/or other individuals concerned.

AMENDMENTS

This policy may be revoked, replaced or changed at any time. Staff will be informed of any material changes made to the policy.