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2018 STOP SLAVERY AWARD QUESTIONNAIRE GOODS COMPANIES

The Stop Slavery Award is an initiative from the Thomson Reuters Foundation. The Award recognizes the “best in class” of the corporate sector: companies that are leading the fight against modern slavery in their supply chains. Conferred for the first time in November 2016 at the annual Trust Conference, the Award honors corporations that go above and beyond their peers in the effort to eradicate forced labor, the worst forms of child labor, and other forms of slavery.

The Stop Slavery Award aims to create a virtuous cycle or positive paradigm by demonstrating that businesses can indeed play a critical role in stopping the tragedy of modern slavery worldwide. Slavery is illegal everywhere. Yet, slavery NGO Walk Free estimates that there are currently 40.3 million people trapped in modern slavery in the world today, but likely very many more than that. This is the largest number of slaves in history.

The global demand for cheap labor is fuelling the slave trade. Market forces create both the supply and the demand for slaves. This is why corporations need to take the lead in the fight. The Stop Slavery Award helps guide consumers’ and customers’ decisions on what goods they decide to buy or use, and raise awareness about the issues of forced labor, the worst forms of child labor, and other forms of modern slavery, inspiring more companies to investigate and improve the working conditions of those at the bottom of their supply chains.

We have chosen to use the term ‘slavery’ for the purposes of the Award to fully encapsulate both the UK Modern Slavery Act’s ‘modern slavery’ definition and the US Federal Acquisition Regulation (FAR) ‘trafficking in persons’ definition, which include all forms of slavery, servitude and forced or compulsory labor, human trafficking, and child labor.

Examples and the full definition of ‘slavery’ are available in Annex A:

• Forced labor includes all work or service that is exacted from any person under the threat of penalty and for which the worker has not offered himself voluntarily including debt bondage and other forms of servitude;

• Other forms of servitude include any practice in which an individual exerts ownership or control over another in such a way as to significantly deprive that person of his or her individual liberty, with the intention of exploiting that person through his or her use, profit, transfer or disposal; and

• The worst forms of child labor, including the ownership, sale, trafficking or forced labor of children; the use, procuring, or offering of children for prostitution, pornography or illicit activities; or the use of children in work which, by its nature or the circumstances in which it is carried out, is likely to harm the health, safety or morals of children as a consequence.

This questionnaire has been specifically tailored for ”Goods Companies”. Service Companies should complete the separate questionnaire here. For the purposes of the Stop Slavery Award, “Service Companies” are those that sell services or intangible goods and products and do not rely on manufacturing or industrial processes in their supply chain and operations. “Goods Companies” are companies that have commodities, or manufacturing, production or industrial processes in their supply chains or operations, or otherwise rely on manual labor. For the avoidance of doubt, all companies that are not Service Companies are considered Goods Companies for the purposes of this Award.

THE STOP SLAVERY AWARD

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In 2018 for the first time, the Stop Slavery Award will recognise winners in two different award categories: Service Companies and Goods Companies. For the purposes of the Stop Slavery Award, “Service Companies” are those that sell services or intangible goods and products and do not rely on manufacturing or industrial processes in their supply chain and operations. “Goods Companies” are companies that have commodities, or manufacturing, production or industrial processes in their supply chains or operations, or otherwise rely on manual labor. For the avoidance of doubt, all companies that are not Service Companies are considered Goods Companies for the purposes of this Award.

There are two different versions of the questionnaire – one for Service Companies and the other for Goods Companies. Please note, this questionnaire has been designed for Goods Companies. If you are a Service company, please complete the relevant questionnaire here.

The questionnaire is intended to identify leadership in all areas integral to robust anti-slavery practices. The questions are designed to highlight best practices relating to different elements of corporate behavior and transparency, focusing on corporate commitment, accountability and transparency, responsible recruitment, supplier engagement, grievance mechanisms, monitoring and corrective action and stakeholder engagement, as well as eliciting responses relating to innovation in the space.

Each question provides bulleted examples of key leadership indicators. These indicators are meant to serve as guidance for content and not as requirements. Please respond to the questions as concisely as possible (400 words or less). There will be an opportunity to upload documents at the end of the process when you are submitting your completed questionnaire. We ask for clear, concise responses with explicit detail on how the policy or program was developed and implemented. The submissions received will be evaluated against an answer matrix to ensure consistency of analysis, with sections weighted differently to allow us to reward those going far beyond compliance.

Unless otherwise specified, please provide answers based on the most recent financial year, or such other 12 month period you prefer to choose. Please ensure that the same 12 month cycle is used for any subsequent submission for the Stop Slavery Award.

These questions are designed to encourage organizations to do more to try to eradicate slavery from their operations and supply chains. The bar has intentionally been set very high, and we do not expect or require that applicants are able to respond affirmatively to every question or to have instituted policies relating to each issue highlighted. We welcome applications from every organisation, irrespective of how comprehensive their activities have been to date, and through the Stop Slavery Awards will look to reward innovative and high impact approaches.

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In the interests of encouraging the sharing of learning amongst companies working to combat slavery in their supply chains and operations, we will share best practice examples of the different questionnaire sections from submissions received from the applicants for the Award. Examples will only be shared with prior approval from the relevant applicant. Names of applicants are strictly confidential; only shortlisted companies will be announced to the public.

For further information please see the Stop Slavery Award website (www.stopslaveryaward.com), or contact the Stop Slavery Award team at stopslaveryaward@trust.org.

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COMPANY INFORMATION

Company Name:

Registered address of Company:

Website:

Location of headquarters (City, Country):

Primary Line of Business:

Please note, this questionnaire has been designed for Goods Companies. If you are a Service Company, please complete the relevant questionnaire here.

For the purposes of the Stop Slavery Award, “Service Companies” are those that sell services or intangible goods and products and do not rely on manufacturing or industrial processes in their supply chain and operations. “Goods Companies” are companies that have commodities, or manufacturing, production or industrial processes in their supply chains or operations, or otherwise rely on manual labor. For the avoidance of doubt, all companies that are not Service Companies are considered Goods Companies for the purposes of this Award.

Industry:

Revenue ($USm): Turnover ($USm):

Financial year end date to which these figures relate:

Permanent employees (FTE): Temporary employees/Contractors (FTE):

Suppliers (no. of companies):

Brief description of company operations and value chain (structure, complexity, geographical spread) –

Questionnaire contact name:

Job Title: Email:

Contact Number: Location:

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SECTION I. CORPORATE COMMITMENT

1. How has the Company publicly demonstrated its awareness and commitment to eradicate slavery? (max 400 words) Examples may include (but are not limited to):

• Publicly available statements and/or policies based on international labor rights conventions are in place expressing commitment to preventing slavery.

• An incorporation of anti-slavery policies in corporate-wide strategies and standards, for example sourcing and purchasing policies.

2. How have senior leadership, the CEO and the board of directors demonstrated public commitment to .......these anti-slavery policies/strategies/initiatives? (max 400 words) Examples may include (but are not limited to):

• Documents, speeches, presentations or other communication have been made by senior leadership, CEO, and/or Board members describing the Company’s position on anti-slavery, its business importance, and its influence on business strategy.

• Anti-slavery is communicated as a clear priority across the Company’s operations and supply chain

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3. How has the Company assigned and established clear responsibilities for the implementation of its anti- slavery policies and standards? (max 400 words)

Examples may include (but are not limited to):

• A team or officer is appointed as responsible for the day-to-day stewardship of anti-slavery activity.• A process is in place to regularly review activities supporting the commitments and policies up to the CEO

and board level.

4. How has the Company implemented objectives and targets to monitor progress in eradicating slavery? (max 400 words)

Examples may include (but are not limited to):

• A formal process has been implemented for developing and managing anti-slavery targets that was developed with input from relevant sector specialists.

• Incentives or performance evaluation processes for senior officials are in place linked to the company’s anti-slavery policies.

SECTION II. ACCOUNTABILITY AND TRANSPARENCY

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5. How does the Company publicly report the details of its progress and any challenges in implementing its anti-slavery policies/programs? (max 400 words)

Examples may include (but are not limited to):

• An annual or semi-annual anti-slavery report is produced with clear objectives and relevant data (e.g., risk assessment results, audit, grievance reports, worker surveys, corrective actions, program challenges/improvements).

• The anti-slavery performance report and supporting documents are reviewed by an internal management team and an independent review is conducted by a qualified, third party.

6. How has the Company implemented training programs to ensure all employees, whether corporate employees or employees at production sites, are aware of risks related to slavery and are effectively implementing these policies and standards? (max 400 words)

Examples may include (but are not limited to):

• Policies and expectations are communicated to employees on a regular basis using a formal communication plan.

• Employees receive anti-slavery specific training with targeted content for new hires, employees involved in supply chain and procurement, and higher risk profiles (e.g., location, type of work).

• Monitoring is regularly performed to ensure employee awareness of the major policy commitments, such as through employee surveys in local language.

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7. How has the Company demonstrated awareness and implementation of responsible recruitment among its production and supply chain? (max 400 words)

Examples may include (but are not limited to):

• Employees are selected, recruited and hired directly using the Company’s own staff.• Recruitment agencies and brokers are required to demonstrate awareness of exploitation among higher risk

workers (e.g., foreign migrant) and a commitment to address such risks as a prerequisite for next engagement.• Suppliers are required to: uphold workers’ rights across all recruiting agencies, directly employ workers, and

provide full disclosure on all recruiters hired.

8. If applicable, how has the Company communicated and monitored responsible recruitment policies with its suppliers, customers, and/or business partners? (max 400 words)

Examples may include (but are not limited to):

• Systems are in place to monitor and audit recruiting agencies to assess risks for slavery. • No fees are charged during any recruitment processes conducted throughout the supply chain. • If fees are discovered to have been paid, there is a due diligence process in place to ensure that all such fees

are reimbursed.

SECTION III. RESPONSIBLE RECRUITMENT

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9. How has the Company trained and ensured that suppliers are aware of risks related to slavery and are effectively implementing company policies and standards? (max 400 words)

Examples may include (but are not limited to):

• A formal process is in place to communicate anti-slavery policy and performance expectations to its supply chain and other business partners.

• Established and documented specific anti-slavery standards and requirements for prospective suppliers are in place.

• Training and capacity building of suppliers is in place on risks, policies, and standards, related to slavery.• Partnerships with stakeholders to educate supply chain workers on labor rights and freedoms (e.g.,

freedom of association and collective bargaining, freedom of movement, retention of documents etc.) have been developed.

10. How has the Company implemented a process demonstrating due diligence in assessment and mitigation of slavery risks throughout its supply chain? (max 400 words)

Examples may include (but are not limited to):

• Public disclosure of how supply chain risk assessments are conducted with details on risks identified in different tiers of its supply chain (e.g., beyond Tier 1).

SECTION IV. SUPPLIER ENGAGEMENT

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11. How has the company established a formal mechanism to report a grievance to an impartial entity regarding slavery in the company’s operations and/or supply chain? (max 400 words)

Examples may include (but are not limited to):

• An easily accessible, proactive and confidential grievance process through an independent party is available for employees, suppliers, customers, or any other external party is in place.

• Grievances are promptly investigated (e.g., root cause) and the results reported to the workforce in a timely manner.

12. How does the Company monitor how empowered workers feel to voice their concerns or identify risks of slavery? (max 400 words)

Examples may include (but are not limited to):

• A process is in place to collect anonymous feedback from workers through an independent third party.• Feedback indicates that employees and supplier workers trust the process.• A commitment to non-retaliation is in place.

SECTION V. GRIEVANCE MECHANISMS

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13. How has the Company implemented a formal process to regularly audit its own operations and those of its suppliers for compliance with both legal and policy requirements related to slavery? (max 400 words)

Examples may include (but are not limited to):

• Audits measuring compliance against regulations and standards are in place. Findings are discussed by senior management and are publicly disclosed in reports (e.g., the percentage of suppliers audited, percentage of unannounced audits, findings, including details regarding any violations).

• Audit effectiveness is independently verified using a third party with expertise in anti-slavery.• The audit program extends beyond direct suppliers to Tier 2 (and lower) high risk suppliers, contractors

and subcontractors.

14. How does the Company process corrective action with suppliers found to be in violation of applicable regulations and/or the company’s standards? (max 400 words)

Examples may include (but are not limited to):

• A formal process is in place to manage non-compliance and non-conformance that includes a means to verify remediation and/or implementation of corrective actions, timelines for remediation and potential consequences if corrective actions are not taken.

• Suppliers and other business partners demonstrate a similar process to address audit findings of their operations

SECTION VI. MONITORING & CORRECTIVE ACTION

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15. How has the Company demonstrated transparency of any violations and its actions to remedy workers and other stakeholders who may be adversely affected by the Company’s operations or that of its supply chain? (max 400 words)

Examples may include (but are not limited to):

• A documented process is in place to remedy adverse impacts to workers caused or contributed by any acts or omission of the Company or its supply chain/business partners.

• The Company is formally engaged with public and/or private initiatives (civil society organizations, industry associations, etc.) to provide improved access to remedy to victims of slavery.

SECTION VI. MONITORING & CORRECTIVE ACTION

SECTION VII. STAKEHOLDER ENGAGEMENT

16. How has the company engaged with relevant stakeholders (local NGOs, government, peer groups, trade bodies) on leading anti-slavery initiatives? (max 400 words)

Examples may include (but are not limited to):

• Active senior leadership participation and/or membership in multi-stakeholder initiatives is in place focused specifically on eradicating slavery. Membership in these initiatives is listed and described on its website or publicly available resource.

• The Company advocates for more protective positions on slavery within its industry or trade association and/or among its peers.

• The Company has demonstrated transparency and open sharing of lessons learned and best practice with peer groups and broader groups.

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17. How has the Company actively supported capacity building of local communities, civil society or government for anti-slavery programs? (max 400 words)

Examples may include (but are not limited to):

• Training is in place for the community, civil society organizations and government agencies on the vulnerabilities of the specific communities and how to identify and address slavery issues.

• Resources are in place for communities and civil society organizations to support awareness-raising and remedy to survivors of slavery (e.g., suitable employment opportunities for survivors of slavery in its facilities or those of suppliers).

18. Please describe recent initiatives and/or significant improvements that demonstrate the Company’s commitment to progressing the eradication of slavery. (max 400 words)

Examples may include (but are not limited to):

• New tools/systems implemented, changes to purchasing or other core business practices developed, new training methods, ways of increasing traceability and engagement beyond Tier 1 etc.

• Being a first mover in initiating efforts (e.g., challenging geographies, complex parts of the supply chain) and in open sharing of lessons learned.

SECTION VIII. INNOVATION

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19. Please describe future targets, goals and/or initiatives that demonstrate the Company’s continued commitment to lead in anti-slavery best practice. (max 400 words)

Examples may include (but are not limited to):

• Examples of industry leading/progressive initiatives that are shifting the anti-slavery field (inclusive of pilot stage programs).

Thank you for taking part in the Thomson Reuters Foundation’s Stop Slavery Award questionnaire, we look forward to reviewing your application.

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The term, ‘slavery’, as used in the Stop Slavery Award Questionnaire encompasses the UK Modern Slavery Act and the US Federal Acquisition Regulation (FAR) definitions for ‘modern slavery’ and ‘trafficking in persons’, respectively.

I. Modern Slavery, as defined in the UK Modern Slavery Act, means when a person:

a) Holds another person in slavery or servitude and the circumstances are such that the person knows or ought to know that the other person is held in slavery or servitude, or

b) Requires another person to perform forced or compulsory labour and the circumstances are such that the person knows or ought to know that the other person is being required to perform forced or compulsory labour

The definition of Slavery and Servitude Slavery, according to the 1926 Slavery Convention, is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised. Since legal ‘ownership’ of a person is not possible, the key element of slavery is the behaviour on the part of the offender asif he/ she did own the person, which deprives the victim of their freedom. Servitude is the obligation to provide services that is imposed by the use of coercion and includes the obligation for a ‘serf’ to live on another person’s property and the impossibility of changing his or her condition.

Forced or compulsory labour is defined in international law by the ILO’s Forced Labour Convention 29 and Protocol.It involves coercion, either direct threats of violence or more subtle forms of compulsion. The key elements are that work or service is exacted from any person under the menace of any penalty and for which the person has not offered him/her self voluntarily.

II. Trafficking in Persons in all severe forms, as used by the US Federal Acquisition Regulations (FAR) is defined as:

a) Sex trafficking in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such act has not attained 18 years of age; or

b) The recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery.

Under the UK’s Modern Slavery Act, the offence of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job or may be a child who is influenced to travel by an adult. In addition, the exploitation of the potential victim does not need to have taken place for the offence to be committed. It means that the arranging or facilitating of the movement of the individual was with a view to exploiting them for sexual exploitation or non-sexual exploitation.The meaning of exploitation is set out here: http://www.legislation.gov.uk/ukpga/2015/30/section/3/enacted.

ANNEX A – DEFINITION OF ‘SLAVERY’