This document defines company policy with regard to compliance with the Modern Slavery Act 2015, section 54, in addition to all existing slavery and human trafficking laws. It includes employer policies for Pivotal BI Limited, and all standards required of suppliers and their supply chain for services procured by Pivotal BI Limited. This includes but is not limited to services such as staff recruitment (both permanent and contract-based employment), creation of bespoke software by third parties commissioned by Pivotal BI Limited, and any other services that are supplied to Pivotal BI directly on a contractual basis. We endeavour to ensure that there is no presence of any exploitation or other forms of modern slavery anywhere within our organisation or that of any of our suppliers and take very seriously the responsibilities of Pivotal BI Limited in these regards.

Forced Labour, Modern Slavery and Trafficking Policies

Pivotal BI Limited operates solely in the United Kingdom, and in doing so reduces some elements of risk associated with exploitation of foreign workers. We do not hire, either directly or indirectly, any low-skilled domestic or migrant workers. We also do not engage with recruiters who hire subcontractors who recruit workers.

In all our business activities, all slavery and human trafficking laws must be complied with, including, but not limited to, the UK Modern Slavery Act 2015. The following policies are enforced by the directors within Pivotal BI Limited to ensure that risks to any occurrence of Modern Slavery or Trafficking are not present within our workforce or the workforce of our supply chain:

All Workers and Suppliers/Agents

Pivotal BI Limited ensures that any workers either directly or indirectly employed (through supply chains) are not subject to any of the following:

• Child labour or the use of minors for the conduct of any services of any kind
• Withholding of worker identity documents or immigration documents by any employer
• Procurement of any commercial sex acts during the length of any associated contract

Furthermore, the following conditions are always confirmed prior to any employment or procurement of services, forming part of any contractual relationships with suppliers:

• Any workers meet applicable legal requirements regarding wage and employment conditions, with wages in accordance with minimal wage requirements.
• Workers are provided with detailed and accurate work agreements in a language understood by the worker.
• Documentation checks (including proof of age documents) are conducted to confirm that workers are allowed to work according to legal standards and related organisational policies

Supplier Requirements

The following conditions must be met by any supplier contracted by Pivotal BI Limited:

• Suppliers must ensure their business operations are free from slavery and human trafficking practices whether in the UK or elsewhere, both internally and within their supply chains and other external business relationships.
• Suppliers must demonstrate commitment to ensuring that there is no modern slavery or human trafficking in their supply chains or in any part of their business.
• All related employment policies of the supplier must be available for inspection to ensure that they comply with the above legislation in all regards.
• Suppliers must be able to demonstrate that processes are in place to undertake due diligence over their supply chain network to ensure compliance with legislative obligations, with this forming part of any contractual relationship with their suppliers.

Recruitment Agency Requirements

Pivotal BI Limited conduct screening of recruiter policies with regard to the Modern Slavery Act 2015, section 54, in addition to all existing slavery and human trafficking laws. In addition to those requirements stated above in Supplier Requirements all recruitment agencies must ensure the following:

• Strict compliance checks are carried for all candidates it supplies. This includes verifying the identity of each worker and their right to work before supply commences.
• All local laws relating to the country in which the recruitment has taken place must be fully complied with.
• In accordance with the “Employers Pay” principle, the charging of fees to workers for recruitment services is not present in any form.

We remain committed to the removal of any likelihood of modern slavery in all our business conducts and those of our suppliers.