Beeline UK Modern Slavery Act and Anti-Human Trafficking Policy

Purpose

Beeline and its subsidiaries and affiliates (the “Beeline Companies”) and their respective governments prohibit acts of modern slavery and trafficking in persons. The U.K. Government’s Modern Slavery Act 2015 prohibiting slavery, servitude, and forced or compulsory labour is available at https://www.legislation.gov.uk/ukpga/2015/30/contents/enacted and is summarized below under the heading: “Summary of the U.K. Modern Slavery Act 2015.” The U.S. Government's policy prohibiting trafficking in persons is available at 48 CFR § 52.222-50 and is summarized below under the heading: "Summary of U.S. Government Policy of Prohibiting Trafficking in Persons."

The Beeline Companies are committed to a work environment that is free from human trafficking and slavery, which for purposes of this policy includes forced labor and unlawful child labor. The Beeline Companies will not tolerate or condone human trafficking or slavery in any part of our global organization.

Employees, subsidiaries, contractors, subcontractors, vendors, suppliers, partners, and others through whom the Beeline Companies conduct business must avoid complicity in any practice that constitutes trafficking in persons or slavery.

Scope

This policy applies to all personnel employed by or engaged to provide services to the Beeline Companies, including, but not limited to, employees, officers, and temporary employees of The Beeline Companies and its U.S. and international subsidiaries, and independent contractors (for ease of reference throughout this policy, "employees").

Every employee is responsible for reading, understanding and complying with this policy. Managers of the Beeline Companies are responsible for ensuring that employees who report to them, directly or indirectly, comply with this policy and complete any certification or training required of them. If you have any questions or concerns relating to this policy, consult Beeline’s human resources department.

Procedures

Report any conduct that you believe to be a violation of this policy to Beeline's human resources department by email: concerns@beeline.com or mail: VP, Human Resources, Beeline, 12735 Gran Bay Parkway West, Suite 130 Jacksonville, FL 32258 United States. Reports may also be made by leaving a detailed message through Beeline’s Ethics Hotline at [00]-1-904-527-5761, which allows anonymous reporting as permitted by applicable law. Beeline employees may make in-person reports at the Jacksonville location to the VP of Human Resources or their HR Business Partner. 

Employees who fail to report actual or suspected misconduct may be deemed in violation of this policy.

Disciplinary Actions

The Beeline Companies will not tolerate retaliation against an employee for reporting a concern in good faith or for cooperating with a compliance investigation, even when no evidence is found to substantiate the report.

Any violation of this policy may be grounds for disciplinary action, up to and including termination. The Beeline Companies have the exclusive right to interpret this policy regarding their respective employees.

Violation of the U.S. Government's policy against human trafficking or the U.K. Government’s policy against acts of modern slavery and trafficking in persons may also result in a criminal prosecution of responsible individuals.

Summary of the U.K. Modern Slavery Act 2015

U.K. Government law prohibits acts of slavery, servitude, forced or compulsory labor, and trafficking in persons and applies to any company doing business in the U.K. (with an annual turnover of £36 million or more and public bodies with a budget of £36 million or more.) 

A statement will need to be published each year describing the steps that the organization has taken to identify, prevent and mitigate modern slavery in its operations and supply chain. The statement will need to cover actions in the following 6 areas:

• Organization and supply chain structure;
• Policies on modern slavery and trafficking in persons;
• Due diligence processes;
• Risk assessment and management;
• Actions were taken to prevent modern slavery (and measurement against performance indicators, if relevant); and
• Staff training on modern slavery and trafficking of persons.

Summary of U.S. Government Policy of Prohibiting Trafficking in Persons

U.S. Government policy prohibits trafficking in persons and slavery. Government contractors and their employees, subcontractors, subcontractor employees, and agents must not engage in any practice that constitutes trafficking in persons or slavery. This includes, but is not limited to, the following activities:

• Engaging in any form of trafficking in persons.
• Procuring commercial sex acts.
• Using forced labor in the performance of any work.
• Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee's identity or immigration documents, such as passports or driver's licenses, regardless of issuing authority.
• Using misleading or fraudulent practices during the recruitment of employees or offering of employment/contract positions, such as failing to disclose, in a format and language understood by the employee or applicant, basic information; or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing, and associated costs (if provided by the employer or agent), any significant cost to be charged to the employee or applicant, and, if applicable, the hazardous nature of the work.
• Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place.
• Charging applicants' recruitment fees.
• If required by law or contract, failing to provide return transportation or failing to pay for the cost of return transportation upon the end of employment.
• If required by law or contract, failing to provide or arrange housing that meets the host country's housing and safety standards.
• If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work documents in writing with the legally required information and in a language the employee understands.

Beeline UK Modern Slavery Act and Anti-Human Trafficking Policy approved by the Beeline Board of Directors and signed on 21st October 2022. Last reviewed on 14th December 2023.