Modern Slavery Policy

18 May 2021

Modern slavery (Anti-Slavery And Human Trafficking):
‘Modern Slavery' is an international crime and a violation of fundamental human rights.  It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.  This global issue transcends age, gender and ethnicities. 


‘Human Trafficking’ involves the recruitment, transfer or obtaining of an individual through coercion, abduction, fraud or force to exploit them. Although human trafficking often involves an international cross-border element, it is also possible to be a victim of modern slavery within your own country. Several broad categories of exploitation are linked to human trafficking, including sexual exploitation, forced labour, domestic servitude, organ harvesting, child-related crimes, forced marriage, and illegal adoption.  It includes victims who have been brought from overseas and vulnerable people who are forced to work illegally against their will.


CodeEast Policy on Slavery and Human Trafficking:
CodeEast has a zero-tolerance approach to Modern Slavery and Human Trafficking. The company's policy is to conduct all of our business in an honest and ethical manner and comply with all applicable legislation. We are committed to ensuring neither Modern Slavery nor Human Trafficking is taking place anywhere in our business, in any of our supply chain or elsewhere in our business environments.


CodeEast Business, Structure and Supply Chain:
CodeEast is a software development company involved in the design and development of Digital Insurance Platforms for the Insurance Industry.  Our mission is to use Smart (Self-service, modularity, Auditability, Real-time and Transformational) Automation to enable insurance companies, MGAs and Brokers Networks to compete, grow, and prosper in the new Digital World.  We have our headquarters in Dublin, Ireland and provide our platform to customers across the USA, Europe and elsewhere.  We use Microsoft’s .NET Core™ as our development environment and host all our customer sites in the Microsoft Azure™ Cloud.  We use in-house software development teams for our New Product Development and system delivery, supplemented by third-party contractors and system integrators companies.


Responsible for Anti-Slavery initiatives:
The board of CodeEast take their obligations relating to Anti-Slavery and Human Trafficking seriously and have therefore appointed one of the company directors, Ambrose Curry, as the Compliance Director with direct and overall responsibility for the day-to-day implementation, compliance, monitoring, training and enforcement of this policy within CodeEast.  Any queries relating to this policy should be directed to Ambrose Curry at acurry@codeeast.com.

 
Whom does this Policy apply to?:
This policy applies to all persons working for CodeEast or on behalf of CodeEast in any capacity, including employees at all levels, directors, officers, developers, suppliers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, system integrator companies, third-party representatives and business partners.


Compliance with this Policy:
All employees, contractors, third party representatives, and others working for or representing CodeEast must read, understand and comply with this policy.  


Reporting knowledge or suspicion of slavery or human trafficking:
The prevention, detection and reporting of modern slavery occurring in any part of our business or in the businesses of our supply chain are the responsibility of all of us working for or under the control of CodeEast. You must report to the company Compliance Director as soon as possible any suspicion, issue or knowledge you have of any such instances within CodeEast or its partners that has occurred, is accruing or may occur in the future. Any disclosures relating to this policy are governed under the CodeEast Whistle-blowers policy, and no employee or partner company who raises such concerns in good faith shall suffer detrimental treatment as a result of such disclosures. 


The provisions of this policy do not replace any legal reporting or disclosure requirements, and where such statutory reporting requirements and procedures exist, such as the Modern Slavery Act 2016 (US), The Modern Slavery ACT 2015 (UK) And The Criminal Law (Human Trafficking) Act (2008 / amended 2013) (Ireland), you and all the employees, officers, third-party representatives and suppliers of CodeEast must comply with them.  
You can contact the Modern Slavery Helpline at 08000 121 700 or via their website at https://www.modernslaveryhelpline.org/.

 
Breaches of this Policy:
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
CodeEast will terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.
Internal Communication and awareness of this Policy:
The Compliance Director will provide electronic access to this policy to each employee and inform them that they are obliged to read and digitally sign it on a yearly basis. 
Each employee of CodeEast is required to acknowledge through the use of their digital signature that they have read, understand, and comply with this policy's provisions.
The topic of Modern Slavery, and our associated Anti-Slavery and Human Trafficking Policy, will be flagged in the induction training undertaken by new staff members starting with CodeEast.
Any update to this policy statement will be communicated to all staff members. 
It is also intended to further highlight the issue of Modern Slavery, to all staff members on Anti-Slavery Day, 18th of October 2021. 


Suppliers 
CodeEast’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.


Policy Review and update
During the calendar year ended 31/12/2020, the CodeEast Compliance Director reported to the CodeEast Management Team that CodeEast had received no reports relating to knowledge or suspicion of slavery or human trafficking within CodeEast or its supply chain. 


On the 4th January 2021, the management of CodeEast reviewed and approved this policy for the year 2021.


CodeEast is committed to reviewing this policy and the company’s compliance with this policy on an annual basis.