Policy Statement

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors,
officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers.

Roma Technology Limited strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have
and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not
taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their
own suppliers to the same high standards.


Modern Slavery and Human Trafficking

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour
and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view
to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.


We shall be a company that expects everyone working with us or on our behalf to support and uphold the following
measures to safeguard against modern slavery:

  • We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
  • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the
    responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any
    activity that might lead to, or suggest, a breach of this policy.
  • We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our
    operations and supply chain.
  • We take a risk based approach to our contracting processes and keep them under review. We assess whether the
    circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour
    in our contracts with third parties. Using our risked based approach we will also assess the merits of writing to
    suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to
    combat modern slavery and trafficking.
  • Consistent with our risk based approach we may require:
    • employment and recruitment agencies and other third parties supplying workers to our organisation to
      confirm their compliance with our Code of Conduct
    • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the
    • As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances
      warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
    • If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that
      we take appropriate action. This may range from considering the possibility of breaches being remediated and
      whether that might represent the best outcome for those individuals impacted by the breach to terminating such
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