Anti-Slavery and Human Trafficking Policy | Perpetio

Anti-Slavery and Human Trafficking Policy

Last updated: October 2023


This Anti-Slavery and Human Trafficking Policy (the "Policy") applies to all team members who work for or on behalf of Perpetio OÜ (hereinafter "the Company", "we" or "our") in any capacity, including but not limited to vendors, contractors, subcontractors, external consultants, third party representatives, clients and business partners. It is important to note that this Policy is not considered to be part of an employment contract, and we reserve the right to amend or cancel it at any time.

Although we are not subject to Section 54 of the Modern Slavery Act 2015 requiring a commercial organisation to prepare a slavery and human trafficking statement for each financial year of the organisation if its total turnover is not less than an amount prescribed by the Secretary of State, we anticipate it as it is possible that our clients may be United Kingdom residents, so we have decided to adopt the Policy as part of our ethical approach to doing business.


Human slavery is a crime and a breach of fundamental human rights in all its forms, which share the same purpose of depriving one person of his or her liberty by another for the purpose of exploitation for personal or commercial gain. We have a zero-tolerance approach to any form of slavery. We are committed to acting ethically and with integrity in all our business dealings and to implementing and enforcing effective systems and controls to ensure that any form of slavery does not occur in our own business or with any of our vendors, partners, customers or potential customers. We expect the same high standards from all of our contractors, subcontractors, vendors, customers, and other business partners and expect them to maintain the same high standards with respect to their vendors.


Our senior management has overall responsibility for ensuring compliance with this Policy across the Company. Operational managers have primary and day-to-day responsibility for implementing this Policy, monitoring its application and effectiveness, responding to any queries regarding it, and auditing internal control systems and procedures to ensure they are effective in combating modern slavery. Managers at all levels are responsible for ensuring that those reporting to them understand and comply with this policy and receive appropriate and regular training on it and on human slavery in supply chains. The overall responsibility for breaches of this Policy is disciplinary action up to and including dismissal or termination of any business relationship, with appropriate reporting of the offence to the relevant government agency with appropriate reporting lines.


Preventing, detecting and reporting incidents of human slavery in any part of our business is the responsibility of everyone who works for us or is under our control. Our team members, contractors, subcontractors, suppliers, customers, partners, and others are required to avoid any activity that may lead to a violation of this Policy. In the event that you believe or suspect that a violation of this Policy has occurred or may occur, you should report it to the CEO as soon as possible. If you are unsure whether a particular action, the treatment of team members in general, or their working conditions at any level of our supply chain constitutes a form of human slavery, raise the issue with the CEO of Perpetio OÜ. We are committed to encouraging openness and will support anyone who raises a genuine concern in good faith under this Policy, even if it turns out to be wrong.


This Policy has been approved by the CEO of Perpetio OÜ, if you would like to receive further information regarding this Policy, please contact the CEO of Perpetio OÜ.