Modern Slavery Policy

This statement applies to all companies within and associated to CIBT Inc (referred to in this statement as ‘The Group’). The information included in the statement refers to the financial year 2024.

Our Business

The Group is a global provider of immigration, visa, and document services for cooperation’s and individuals worldwide. Our corporate head office is located in London Union Street, we have regional offices in Australia, Brazil, Canada, China, India, Mexico, the Netherlands, Singapore, and the United States. The Group’s network of in-country partners are regulated by the standards of legal practice in their country of operation, with standards that typically uphold and dictate exemplary ethical behavior and conduct concerning the rights of and, thereby the protection of human beings in any area that may be considered as slavery.

Definitions

The Group considers that modern slavery encompasses:

•   Human trafficking;
•   Forced work through mental or physical threat;
•   Being owned or controlled by an employer through mental of physical abuse;
•   Being dehumanized, treated as a commodity, or being bough or sold as property;
•   Being physically constrained or to have restriction placed on freedom of movement.

Commitment

The Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Group understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Group does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Network Partners

The Group works with a network of global partners. We conduct due diligence on all prospective partners, including an online check to ensure that particular organisation has never been convicted of offenses relating to modern slavery. We also have mandatory compliance training for partners that we require all team members working with The Group, to complete and acknowledge.

In addition to the above, as part of our contract with network partners, we require that they confirm to us that they commit to the following business practices:

1.   They pay their employees at least the national minimum wage / national living wage in the country of operations;
2.   None of their employees are required to lodge “deposits” or identity papers with them and that they are free to leave their employment after reasonable notice;
3.   They commit to the abolishment of child labour and guarantee that nobody is employed under the minimum legal age for employment.;
4.   They observe the right to reasonable remuneration on the basis of a contract in line with the respective national labour market, stipulating at least the minimum wages guaranteed by law;
5.   5They guarantee the observance of the respective national regulations on hours of work and on regular paid holiday;
6.   They protect the health and safety of employees by complying with the standard applicable in their country. This includes access to clean toilets, drinkable water and, if applicable, clean facilities for food storage;
7.   They treat employees with respect and dignity. The Group reserves the right to check the observance of these principles in a suitable manner if there is a well-founded suspicion to do so and will terminate the contract at any time should any instances of modern slavery come to light.

In general, The Group considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, we have taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and services to it.

Steps

The Group carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Group has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery. In accordance with section 54(4) of the Modern Slavery Act 2015, the Group has taken the following steps to ensure that modern slavery is not taking place:

•   Continuously evaluating the effectiveness of our systems, including exploring opportunities to expand our whistleblowing policy externally;
•   Tracking the attendance, and completion of specific and mandatory training modules around forced labour and human trafficking for all The Groups employees;
•   Thoroughly and regularly reviewing suppliers to identify and mitigate potential risks in supply chains.

The Group is committed to uncompromising integrity and the highest standards of ethical conduct. We have a global whistleblowing policy and program, allowing team members to email or call a confidential hotline to report any action or behavior that does not align with our commitment to ethics, conduct, safety and compliance, or is in violation of policy. The Company monitors all activity to the hotline and conducts investigations as appropriate.

Our Performance Indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if no reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

Our Policies

We enforce a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These policies include:

1.   Recruitment policy. We operate a robust recruitment policy, including conducting eligibility verifications to work in the country of hire.
2.   Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, anonymously and without fear of reprisals.
3.   Internal compliance training. We have a robust and mandatory compliance training package in place for all employees working on global immigration matters.

Training

The Group provides the following training to staff to effectively implement its stance on modern slavery:

•   New Hire Essentials Training: Anti-Bribery, Ethics, Harassment, Discrimination, Sanctions;
•   Quarterly Training Session.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

This statement was approved by:

Steven Diehl, September 2024

Chief Executive Officer