Modern slavery policy

Last updated 01.01.2017

Introduction

This Modern Slavery and Human Trafficking Statement relates to actions and activities since 01.01.2017.

The statement sets down Grabyo’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small.  Staff are expected to report their concerns and management to act upon them.

Organisational structure and supply chains

This statement covers the business activities of Grabyo which are as follows:

  1. Enterprise video software-as-a-service – providing a cloud-based hosted service to enable clients to produce, edit and distribute video.

The Company currently operates in across the globe, predominantly in the EU and US.

All of Grabyo’s staff are based in the UK. Grabyo has a wholly owned subsidiary, Grabyo Inc, which employs staff in the US.

Grabyo assesses whether particular activities or countries are high risk in relation to modern slavery or human trafficking at a board level for any concerns raised.

Responsibility for the Company’s anti-slavery initiatives is as follows:

  • Policies: The CEO is responsible for creating and reviewing policies. The process by which policies are developed is looking at best practice and adapting to the needs of the Company.
  • Risk assessments: The CEO is responsible for risk assessments in respect of human rights and modern by a process of raising concerns for any prospective clients or suppliers with the Board.
  • Due diligence: The CEO is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.

Training

To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all management staff to familiarise themselves with Grabyo’s anti-slavery policy.

Policies

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

  • Whistleblowing Policy – Grabyo encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
  • Grabyo Employee Handbook – sets down the actions and behaviour expected of employees when representing Grabyo.
  • Due Diligence Processes for Slavery and Human Trafficking

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners AND/OR evaluating the modern slavery and human trafficking risks of each new supplier AND/OR invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

Performance indicators

Grabyo measures how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains by requiring all relevant staff to have familiarised themselves with Grabyo’s policies, and logging all reported concerns around slavery and human trafficking, together with the action taken.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Management Team endorses this policy statement and is fully committed to its implementation.

This Modern Slavery and Human Trafficking Statement has been approved and authorised by:

Name: Gareth Capon
Position: CEO

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