At the International Center for Trade Transparency Limited (“ICTT,” “we,” “us,” or “our”), we are committed to respecting human rights and combatting modern slavery in all its forms. This Human Rights and Modern Slavery Policy Statement (“Policy”) outlines our approach to ensuring that our activities and those of our partners are conducted ethically and in compliance with applicable laws, including the United Kingdom’s Modern Slavery Act 2015.

Scope

This Policy applies to all our employees, officers, directors, and representatives, as well as our contractors, suppliers, and other third parties with whom we have business relationships.

Our Commitment

Respect for Human Rights

We are dedicated to upholding and promoting human rights as set forth in the Universal Declaration of Human Rights and the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work. We recognize our responsibility to respect human rights throughout our operations and are committed to conducting our business in a manner that does not infringe on these rights.

Combatting Modern Slavery

We are committed to taking all necessary steps to prevent and eradicate modern slavery, including forced labor, child labor, human trafficking, and other forms of exploitation, within our organization and our supply chain. We have zero tolerance for any form of modern slavery and will take appropriate action against any individuals or entities found to be engaging in such practices.

Our Actions

Due Diligence and Risk Assessment

We conduct regular due diligence and risk assessments to identify, prevent, and mitigate any potential human rights abuses or modern slavery risks within our organization and our supply chain. We also assess the effectiveness of our efforts and implement any necessary improvements to our policies and procedures.

Supplier and Partner Standards

We expect our suppliers, contractors, and other partners to share our commitment to human rights and modern slavery prevention. We require these parties to comply with all applicable laws and adhere to our standards, as outlined in this Policy, and reserve the right to terminate our relationship with any party that fails to meet these requirements.

Training and Awareness

We provide training and raise awareness among our employees, officers, directors, and representatives about the importance of human rights, the risks of modern slavery, and our responsibilities under this Policy and applicable laws. We also encourage our suppliers and other partners to provide similar training and awareness programs within their organizations.

Reporting and Remediation

We encourage our employees, partners, and stakeholders to report any actual or suspected human rights abuses or modern slavery practices involving our organization or our supply chain. We provide a confidential reporting mechanism and are committed to investigating all reported concerns promptly and thoroughly. We will take appropriate action to address any confirmed violations and will work to remediate any adverse impacts on affected individuals or communities.

Compliance and Monitoring

We regularly review and monitor our compliance with this Policy, applicable laws, and international standards on human rights and modern slavery prevention. We are committed to continuous improvement in our efforts to prevent and address any potential risks or violations.

This Human Rights and Modern Slavery Policy Statement is subject to regular review and may be updated from time to time to reflect changes in our operations, applicable laws, or international best practices. Any changes will be posted on this page, and your continued use of our services or the website following such changes constitutes your acceptance of the revised Policy.

If you have any questions or concerns about this Policy or our practices related to human rights and modern slavery, please contact us at [email protected].