Modern Slavery Policy.

1. INTRODUCTION

Origina is a global software services provider. We are committed to doing business lawfully, ethically, and with respect for human rights. That includes taking steps to prevent modern slavery in our business and supply chains. This Policy explains our approach to preventing modern slavery. It sets out our commitments, the controls we use, and what we expect from our people and suppliers.

 

2. WHAT IS MODERN SLAVERY

Modern slavery can take many forms, the most common of which are:

• Child Labour: Is any individual under the minimum legal age of employment within the jurisdiction in which they work.
• Forced, Bonded or Involuntary Labour: Involved the use of forced, bonded (also referred to as debt bondage), indentured or compulsory labour, or involuntary prison labour or involvement in human trafficking. All employees must be able to resign freely without any penalties, in accordance with local and national laws or regulations.

 

3. FRAMEWORK TO COMBAT MODERN SLAVERY

We recognise that modern slavery risk needs active oversight. We use clear policies, controls, and governance to help prevent it. This Policy is supported by internal controls and processes designed to reduce modern slavery risk across our business and supply chain. These include:

• Leadership and accountability
• Governance and oversight
• Training and awareness
• Business risk assessment
• Employee, customer, vendor and third-party due diligence
• IT systems and security requirements
• Internal and external reporting and recordkeeping
• Independent review of policies and procedures

 

4. OUR APPROACH TO MODERN SLAVERY
Origina as an employer takes, and expects our suppliers to take, sufficient steps to prohibit practices that are known to contribute to the risk of modern slavery.

 

4.1 Origina Employees

We comply with employment laws wherever we operate. We keep the documents needed to confirm legal working status and age. Our recruitment and onboarding processes include identity, background, and right-to-work checks. These controls help reduce the risk of modern slavery in our workforce.

 

4.2 Suppliers

Our supply chain is diverse. Most of our spend is in professional sectors such as technology, marketing, payment services, and consulting, which are generally lower risk. Even so, we continue to assess and monitor modern slavery risk. Some externally sourced services may present higher risk, including cleaning and facilities management, apparel sourcing for marketing, and technology hardware where temporary, transient, or migrant labour may be used. As part of vendor screening, we assess potential vendors on ESG matters, including human rights and modern slavery. If we identify gaps, we will only engage the vendor once satisfactory corrective action is agreed and time-bound. Vendors must also have appropriate safeguards in place, including the following:

• Background and identity verification checks, including confirmation of right-to-work documentation, are undertaken.
• If child labour is identified, Origina must immediately be informed and all necessary remedial steps should be taken by the Vendor to the child's welfare and their gradual transition into schooling.
• Payment of wages to employees is not withheld.
• Employees will never be required to pay recruitment costs, fees or financial deposits to the Vendor or a third party even in instances where recovery of recruitment costs is permitted under local law (e.g. foreign worker levies).
• Any recruitment fees found to be paid by workers to the Vendor or a third party are immediately reimbursed by the Vendor.
• Confidential internal reporting and whistleblowing channels are in place to facilitate any known or suspected instances or risks of modern slavery being reported to the Vendor's senior management. Communication and training with respect to these channels should be provided to all employees.

Vendors must comply with applicable laws relating to modern slavery, provide relevant information or supporting evidence on request, notify Origina promptly of any actual or suspected breach, investigation, or material risk in their operations or supply chain, and where appropriate apply equivalent standards to relevant subcontractors and other third parties.  

 

5. ROLES AND RESPONSIBILITIES

5.1 Management

Senior management is responsible for overseeing and implementing this Policy. It must ensure appropriate training, resources, and periodic updates are in place. Where third-party screening providers are used, senior management is responsible for their selection and for maintaining any required licences. Where a concern is identified, Origina will assess it promptly and take proportionate action. That may include internal escalation, further due diligence, investigation, remediation planning, supplier corrective action, suspension of engagement, or termination where appropriate. Relevant records will be maintained in line with applicable policies and legal requirements.

 

5.2 Employees

Employees must read this Policy, complete any training provided, and understand how to identify and report concerns. Any suspected breach or wrongdoing must be reported to the Chief Risk Officer or the employee's line manager, as appropriate. Concerns may also be raised through any applicable whistleblowing or speak-up channels. Reports will be handled as confidentially as possible, consistent with a fair and proper investigation. Origina does not tolerate retaliation against anyone who raises a concern in good faith or supports an investigation.  

 

6. AWARENESS AND REVIEW

Origina will provide appropriate awareness materials on this Policy and modern slavery risk, taking account of role and risk exposure. This Policy will be reviewed periodically, and in any event at least annually, to ensure it remains appropriate for Origina's business, supply chain, and legal obligations. It may also be reviewed following a material incident, a significant change in operations, or a relevant change in law or regulatory expectations.

 

7. RELEVANT CONTACT DETAILS

Questions about this Policy should be directed to:

Responsibility	Email
General Counsel & Chief Risk Officer	[email protected]
Head of People & Culture	[email protected]