Vinovium Associates Ltd strictly prohibits employees, subcontractors, subcontractor employees, and agents from engaging in human trafficking-related activities. These activities include engaging in sex trafficking, procuring commercial sex acts (even if this practice is legal in the jurisdiction where it transpires), using force, fraud, or coercion to subject a person to involuntary servitude, or obtaining labour from a person by threats of serious harm to that person or another person, among others.

Vinovium Associates Ltd also prohibits employees, subcontractors, subcontractor employees, and agents from engaging in practices relating to trafficking in persons, including:

• Destroying or otherwise denying access to an employee’s identity or immigration documents;

• Using misleading or fraudulent practices to recruit employees, such as failing to disclose key terms and conditions of employment;

• Using recruiters that do not comply with local labour laws;

• Charging employees recruitment fees;

• Failing to provide return transportation to certain employees who are brought to a country for the purpose of working on a U.S. Government contract;

• Providing housing that fails to meet host country standards; and

• Failing to provide an employment contract or work document where required by law.

 

Vinovium Associates Ltd will take appropriate disciplinary action for violations of these rules, up to and including discharge of employees, subcontractors, and agents.

 

Vinovium Associates Ltd will cooperate fully with the appropriate governmental authorities in audits or investigations relating to such violations. Employees of Vinovium Associates Ltd are required to cooperate in any internal or external investigation of suspected wrongdoing under this policy.

 

Mandatory Reporting Requirements

Employees having knowledge of credible information concerning actual or potential violations of this policy must report them immediately in accordance with the Vinovium Associates Ltd

 

Escalation Procedure

Timeliness of reporting any suspected violation is critical as the Government has imposed an especially stringent reporting obligation when there is credible information of violations. Failure to report actual or potential illegal behavior or actual or potential violations of this policy may also subject employees to disciplinary action, up to and including termination of employment.

Vinovium Associates Ltd has a number of channels available to receive reports of possible violations of policy.

 

Escalation Procedure

Employees may also report possible violations to line management, human resources, compliance professionals throughout the organisation. Any person who receives reports of possible violations under this policy must notify one of the Directors immediately. When making a report, employees are encouraged to share as much information as possible so that appropriate action can be taken.

In addition to the reporting requirements described above, it is possible for Vinovium Associates Ltd employees to report activity inconsistent with this policy to a third-party managed hotline. Such reporting does not satisfy an employee’s obligation to report to Vinovium Associates Ltd credible information concerning actual or potential violations of this policy immediately, in accordance with the Vinovium Associates Ltd Escalation Procedure.

 

Non-Retaliation Policy

Vinovium Associates Ltd does not tolerate retaliation or threats of retaliation against anyone who raises a concern under this policy or who assists with an internal or governmental audit or investigation. Any employee who engages in retaliation or threats of retaliation will face disciplinary action, which could include termination of employment.