Modern Slavery Policy

INTRODUCTION

BulkSMS ("the Company") is committed to combating modern slavery and human trafficking in all its forms. This Modern Slavery Policy reflects our dedication to acting ethically and responsibly and outlines the measures we take to ensure that modern slavery is not present within our operations or supply chains.

POLICY STATEMENT

The Company prohibits all forms of modern slavery, including forced labour, child labour, human trafficking, and any other exploitative practices. We are committed to respecting and promoting human rights, both within our organization and throughout our supply chain.

SCOPE

This policy applies to all employees, contractors, suppliers, and business partners acting on behalf of the Company ("Covered Parties"). It encompasses all business activities, both domestically and internationally.

COMPLIANCE WITH LAWS

The Company is committed to complying with all applicable laws and regulations related to modern slavery, including the Modern Slavery Act 2015 in the UK; the Constitution of South Africa 1996, Prevention and Combating of Trafficking in Persons Act 2013, the Basic Conditions of Employment Act of 1997 (BCEA), as amended in 2014, and other relevant international laws.

RISK ASSESSMENT

The Company will conduct regular risk assessments to identify and evaluate the risk of modern slavery within our operations and supply chains. Appropriate measures will be implemented to address and mitigate identified risks.

DUE DILIGENCE

The Company will implement due diligence processes to assess and monitor suppliers and business partners. This includes ensuring that our supply chain partners share our commitment to eradicating modern slavery and comply with relevant laws and regulations.

REPORTING SUSPECTED VIOLATIONS

Covered Parties must promptly report any suspected violations of this Modern Slavery Policy to their manager, the Compliance Officer, or through the established reporting channels. The Company encourages reporting without fear of retaliation.

TRAINING AND AWARENESS

The Company is committed to providing training and resources to ensure that all Covered Parties are aware of and understand the provisions of this policy, as well as the risks and indicators of modern slavery. Employee training will be provided regularly.

MONITORING AND REVIEW

The Company will implement monitoring mechanisms to assess the effectiveness of our efforts in combating modern slavery. Regular reviews will be conducted to ensure compliance and identify areas for improvement.

COMMUNICATION AND TRANSPARENCY

The Company will communicate openly and transparently about its efforts to combat modern slavery. This includes providing relevant information to stakeholders, customers, and the public about our policies, practices, and progress.

CONSEQUENCES OF VIOLATIONS

Violations of this Modern Slavery Policy will result in disciplinary action, which may include termination of employment, termination of contracts, and potential legal action. The severity of the consequences will depend on the nature and extent of the violation.

REVIEW AND UPDATE

This policy will be periodically reviewed to ensure its effectiveness and relevance. Amendments may be made to reflect changes in applicable laws or business practices.

RESPONSIBILITIES FOR THE PROCESS

The responsibilities for the preparation, verification, issue, filing and up-dating of this policy and associated processes is the duty of the Director: Operations or duly appointed representative. The monitoring, measuring and continual improvement of the procedure or process is the responsibility of the Compliance Officer or duly appointed representative.