1. Purpose

1.1 The Clickatell Group adopts a zero tolerance approach to Modern Slavery and is committed to upholding and respecting human rights within the workplace. To achieve this, Clickatell employs measures to identify and mitigate the risks of Modern Slavery which may occur in its supply chain and daily operations. This Policy outlines the measures to be enforced, upheld and respected by Clickatell’s employees, agents, contractors, suppliers and stakeholders.

The Policy further addresses the steps taken by Clickatell to ensure that it is compliant with Anti-Slavery legislation, including the Basic Conditions of Employment Act 75 of 1997 in South Africa, Modern Slavery Act of 2015 in the United Kingdom and similar legislation.

2. Scope

2.1 This policy is applicable to all Clickatell employees, stakeholders and suppliers.

3. Policy

In accordance with the commitments set out in this Policy, Clickatell implements the following Anti-slavery measures:

3.1 Modern Slavery Statement

3.1.1 An annual Modern Slavery Transparency Statement, as approved by the Social and Ethics Committee and signed by an authorized representative will be published within six months of each financial year. The statement will contain the steps, if any, taken by Clickatell during said financial year to ensure adherence to this Policy. A copy of the statement will be made available on the website.

3.2 Supply Chain Management

3.2.1 To mitigate risks of any exposure to Modern Slavery in the supply chain Clickatell conducts a risk assessment to determine the areas of its supply chain which is most susceptible or at risk of non-compliance with Modern Slavery legislation.

3.2.2 Prior to the utilisation of any supplier, a due diligence is conducted on the supplier. This process includes identifying the anti-slavery measure the supplier has implemented.

3.2.3 Clickatell requires that its suppliers adopt an approach to Modern Slavery and human rights within the workplace which aligns with the principles set out in this Policy.

3.3 Recruitment

3.3.1 We ensure that the recruitment carried out by the Clickatell Human Resources Department is done in a lawful and ethical manner. This includes conducting comprehensive background checks on all applicants, concluding written contracts of employment with successful applicants and ensuring that the applicant has not paid any direct or indirect fees to obtain the position.

3.3.2 Where the services of recruitment agencies are utilised, due diligences are conducted to ensure that the methods used by the agencies are lawful. If, during the recruitment process the applicant suspects that they are being exploited, the applicant may report the alleged conduct to the contact person identified in clause 4.2 below.

3.3.3 Clickatell expressly prohibits conduct which may amount to the use of child labour, forced labour or human trafficking. If an employee or third party becomes aware of slavery or human trafficking within any aspect of our supply chain or business operations, they are encouraged to report this to the contact person identified in clause 4.2 below.

4.      Policy Compliance

4.1 Compliance Measurement

4.1.1 Each employee is responsible for ensuring that they have read and comply with this Policy.

4.1.2 Managers are responsible for ensuring that those reporting to them are aware and comply with this Policy. Managers must ensure that all notifications received of alleged breaches to this Policy are dealt with in the appropriate manner.

4.1.3 The Policy will be reviewed at least every two years and updated as is required to bring the policy in line with new developments in Anti-slavery legislation.

4.2 Duty to report

4.2.1 Clickatell employees who become aware of or suspect that a breach of this Policy may have occurred, must report the alleged breach to their reporting managers as soon as possible. Should the employee wish to remain anonymous the employee may report the alleged breach to Minde Schapiro & Smith Inc, who may be contacted on +2721 918 9000.

4.2.2 Suppliers, clients and other third parties who believe or suspect that a breach of this Policy has or may occur, can report the alleged breach to legal@clickatell.com.

4.2.3 All notifications received will be treated as confidential and dealt with as per the procedures set out in the Whistleblowing Policy.

4.3.1 Any employee found to be acting in breach of this Policy will be subject to disciplinary action, which may include dismissal.

4.3.2 Clickatell further reserves the right to terminate any contractual agreement or commercial arrangement with any supplier, contractor, agent or partner who is found to be in breach of this Policy.

5 Related Standards, Policies and Processes

5.1 POL039 – Whistleblowing Policy

6 Definitions and Terms

6.1 Child labour: where a child under the age of 18 years is exploited for labour. Child labour is in relation to work that deprives children of their childhood, their dignity and is mentally, physically or morally dangerous to children.

6.2 Forced labour: work performed, or services provided against someone’s will and/or under threat of punishment to themselves or their family.

6.3 Human trafficking: exploitation of people through forced prostitution, labour, marriage, criminal activities or organ removal. Often threats of violence or coercion are used to harbour or recruit victims of human trafficking.

6.4 Modern Slavery: the exploitation of individuals for personal or commercial gain through coercion, misrepresentation or force.

6.5 Slavery: where someone exercises powers attaching to the right of ownership over another person. This includes the power to make the victim an object of purchase.