AVI-SPL Global Anti-Slavery, Forced Labour, and Child Labour Policy

 

Purpose

AVI-SPL is committed to the highest standards of ethical conduct, including the prevention of forced labour, child labour, and modern slavery in its operations and supply chain. This policy outlines our global commitment and the steps we take to identify, prevent, and mitigate these risks, aligning with requirements such as the United Kingdom’s Modern Slavery Act 2015 and Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act.

Scope

This policy applies to all global operations across all AVI-SPL employees, directors, trustees, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, suppliers, and business partners.

Definitions
  • Slavery: Exercising powers of ownership over a person.
  • Servitude: Obligation to provide services imposed by coercion.
  • Forced or compulsory labour: Work or services exacted under threat or penalty.
  • Human trafficking: Arranging or facilitating travel of a person for exploitation.
  1. 1. Company Commitment

AVI-SPL maintains a zero-tolerance approach to all forms of modern slavery, human trafficking, forced labour, and child labour. We are committed to ethical practices throughout our operations and supply chains.

  1. 2. Organizational Structure and Supply Chain

AVI-SPL is a global provider of digital enablement and collaboration technology solutions. We operate in over a dozen countries with more than 4,500 employees and 70 offices. Our supply chain includes AV, UC, and workplace technology suppliers, distribution, and transportation service providers.

  1. 3. Relevant Policies
  1. 4. Due Diligence and Risk Assessment

AVI-SPL conducts due diligence to assess risks in our operations and supply chain, including:

  • Annual review of supplier compliance with our Supplier Code of Conduct.
  • Training procurement and HR staff on modern slavery risks and ethical recruitment practices.
  • Monitoring supply chains for geographic, sector, and supplier-level risks.
  • Conducting pre-employment right-to-work checks and only using reputable recruitment agencies.
  • Reference to UK Government’s and Canada procurement guidance.
  1. 5. Responsibilities
  • Organizational: Implement policies and procedures
  • Managerial: Stay alert and act on concerns
  • Individual: Remain vigilant and report
  1. 6. Identifying and Reporting Slavery

The prevention, detection, and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for AVI-SPL or under our control. Signs that may identify potential forced labour include:

  • Lack of identification documents
  • Others speaking for the individual
  • Being dropped off and collected from work
  • Withdrawal, fearfulness, limited interaction

 

Those who have a concern or suspicion that modern slavery may be taking place in any part of our business or supply chain must raise it promptly with a member of AVI-SPL Executive Management or the local AVI-SPL Human Resources representative.

AVI-SPL employees, contractors, vendors, or suppliers worldwide can report concerns of forced labour, slavery, or child labour via AVI-SPL’s reporting portal at https://avispl.allvoices.co/ and externally through the UK modern slavery helpline.

 

  1. 7. Risk Management

AVI-SPL assesses the risk of forced labour and child labour through:

  • Reviewing supplier practices and sourcing countries.
  • Evaluating new suppliers and contracts against our ethical standards.
  • Conducting targeted risk assessments in high-risk geographies and industries.
  1. 8. Remediation

To date, AVI-SPL has not identified instances of forced labour or child labour in our operations or supply chain. In the event of such a finding, AVI-SPL will:

  • Investigate the issue and require corrective action from the supplier.
  • Terminate relationships if remediation is not possible.
  • Address potential loss of income to vulnerable families where applicable.
  1. 9. Training and Awareness

AVI-SPL provides training on forced labour, modern slavery, and child labour to:

  • All employees globally through our Code of Conduct and HR compliance training.
  • Key staff involved in procurement and recruitment through targeted learning modules.
  1. 10. Monitoring and Effectiveness

AVI-SPL evaluates the effectiveness of its efforts through:

  • Annual internal policy reviews.
  • Tracking employee training participation.
  • Monitoring supplier compliance and auditing high-risk areas when needed.
  • Evaluating anonymous reporting via our third-party ethics platform, AllVoices.
  1. 11. Communication

This policy is shared internally with all employees and made available to external stakeholders on our website. It is reviewed annually and updated as necessary to reflect regulatory or operational changes.

  1. 12. Governance and Approval

The AVI-SPL Executive Management Team is responsible for approving this policy and overseeing policy implementation; reviewed alongside the United Kingdom Modern Slavery Statement and Canadian Forced Labour and Child Labour reports.

Effective Date: 9 May, 2025