MODERN SLAVERY AND HUMAN TRAFFICKING POLICY APRIL 2019

MODERN SLAVERY AND HUMAN TRAFFICKING POLICY

POLICY STATEMENTModern slavery is a 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 in order to exploit them for personal or commercial gain.

We are committed to improving our practices to combat slavery and human trafficking

ACAL has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our value chains.

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SLAVERY, SERVITUDE & FORCED LABOUR.Article 30. of the Constitution of Kenya 2010 (1) A person shall not be held in slavery or servitude. (2) A person shall not be required to perform forced labour.

APPLICATION AND COVERAGE This policy applies to all persons working ACAL or on our behalf in any capacity, including employees at all levels, directors, officers, associates, interns, agents, contractors, representatives and business partners.

OUR SCOPE OF SERVICES ACAL is private Limited company, incorporated in Kenya. Its core business is management consulting within the republic of Kenya in;

– Strategy and advisory

– Research and assessments

– Training and Capacity building

– Human Resource Management services

Within our service value chains we have ensured that the requirements of Constitution of Kenya 2010 are complied with regarding slavery servitude and forced labour.

We are committed to ensuring that there is no modern slavery or human trafficking in our service value

chains or in any part of our business.

In light of the obligation to report on measures to ensure that all parts of our business service value chains are slavery free and therefore this policy and have reviewed our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues.

ACAL`S Modern Slavery and Human Trafficking Policy demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our value chains.

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DUE DILIGENCE OF PROCESSES TO AVERT MODERN SLAVERY AND HUMAN TRAFFICKING As part of our initiative to identify and mitigate risk we have in place systems to:

– Identify and assess potential risk areas in our service value chains

– Mitigate the risk of slavery and human trafficking occurring in our business

– Monitor potential risk areas in our business

– Protect whistle blowers as per the ACAL whistleblowing policy

POLICY The Board of Directors have overall responsibility for ensuring this policy with senior management; and managers have day to day responsibility to ensure compliance with our legal and ethical obligation

The Country Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and ensure effective countering modern slavery. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

COMPLIANCE WITH THIS POLICY You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business and the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your manager or Country Director as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

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BREACHES OF THIS POLICY Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. ACAL may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy

REVIEWThis policy will be reviewed on an annual basis to ensure continuing suitability.

ACAL ConsultingVictoria Office SuitesRiverside DrivePO Box 20382 - 00100Nairobi, Kenya

T +254 (0) 20 201 3480, 3488E info@acalconsulting.co.ke

About ACALWe go deep to unlock insight and have the courage to act. We bring the right people together to challenge established thinking and drive transformation. We work with our clients to build the capabilities that enable organizations to achieve sustainable advantage. We are shaping the future. Together. See how we change the game at acalconsulting.co.ke