Anti-Slavery and Human Trafficking Policy

Ontotext is committed to preventing modern slavery and human trafficking from affecting any part of our business or those of our suppliers.

1. Purpose

1.1 Modern slavery is a criminal offense under the Modern Slavery Act 2015 (the “Act”). Modern slavery can occur in various forms, including servitude, forced or compulsory labor 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. This document sets out the policy of Ontotext (the “Company”) with the aim of the prevention of opportunities for modern slavery to occur within its businesses or supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Act.

1.2 As a company, we have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own businesses or those of our suppliers.

2. Scope

This policy applies to all persons working for Ontotext or on our behalf in any capacity, including partners, employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

3. Responsibility for the Policy

Anti-Slavery and Human Trafficking Policy

3.1 Ultimate responsibility for the prevention and prevention of modern slavery rests with the Company’s management. The board of directors of the Company has overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations.

3.2 Team Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery.

4. Compliance with this policy

4.1 All partners and employees must read, understand and comply with this policy. Everyone working for Ontotext is responsible for preventing, detecting and reporting modern slavery if it is encountered.

4.2 If anyone becomes aware of or suspects that modern slavery is taking place, they must immediately notify our management. This applies whether or not the suspected slavery involves Ontotext or one of its third party suppliers.

4.3 We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

5. Communication and Awareness

5.1 The company provides training on this policy as part of the induction process for all individuals who are involved in the appointment of suppliers. All staff will be notified of this policy on joining and receive training as appropriate from time to time.

5.2 We also communicate this policy to all suppliers, contractors and business partners at the outset of our business relationship with them.

6. Breaches of this Policy

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

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