Version: 0.3
Last Amendment:

November 2023
Next Review:

November 2024

Prevention of Modern Slavery
PolicyGLB-HR-23-11-INT

Department:

People & Culture
Contact:

jbinnion@keywordsstudios.com

To be read in conjunction with:Protected Disclosures (Whistleblowing) Policy

CONFIDENTIAL AND PROPRIETARYEXECUTIVE SUMMARY
1.

For any business travel, reason should prevail. People should manage their bookings and expenses
as if it was their own money.

2. We shouldn’t travel if we don’t need to: that’s better for our finances and that’s better for theplanet.
3. Where the Navan platform is available, its usage to manage travel and hotel bookings will bemandatory.
4. Seat reservation options can be flexible depending on your band in the Group, but by default, weshould always try to limit ourselves to economy classes.
5. All travel and expenses need to be approved by your manager. Please do so ahead of booking a newtrip.
6. All exceptions to this policy should be approved by an ExCo member.

Document Title

Document No.

VersionGLB-HR-23-11-INT
Prevention of Modern Slavery Policy

0.3

Last Revision DateNov. 18, 23

Page 1 of 6

Document History
DateVersion

DescriptionAuthor

01/01/2018

0.1

First Draft

Gerry Cleary

12/16/2019

0.1

Reviewed, no changes

Gerry Cleary

12/14/2020

0.1

Reviewed and Approved

11/29/2021

0.2

Replaced ‘company’ with ‘group’. Section 8/Furthersteps adjusted to include our annual process.

13/11/2023

0.3

Minor changes and design update

13/11/2023

0.3

Reviewed and Approved

Audit Committee
Gerry Cleary
Ekaterina Ustina
Risk & Compliance
Committee

CONFIDENTIAL AND PROPRIETARY - Proprietary notes apply. Printed documents are subject to change. Verify correct revision before use.
PROPRIETARY NOTE: This document contains information proprietary to Keywords Int’l. Any disclosure or use is expressly prohibited, except upon explicit written permission.

Document Title

Document No.

Version

GLB-HR-23-11-INT
Prevention of Modern Slavery Policy

0.3

Last Revision Date

Nov. 18, 23

Page 2 of 6

Table of Contents
1.

Aims ........................................................................................................................................................................ 3

2.

Scope...................................................................................................................................................................... 3

3.

Review .................................................................................................................................................................... 3

4.

Feedback................................................................................................................................................................ 3

5.

INTRODUCTION ..................................................................................................................................................... 3

6.

Definition ................................................................................................................................................................ 37.

Due diligence process and mitigation risk.......................................................................................................... 4

8.

FURTHER STEPS .................................................................................................................................................... 4

9.

RESPONSIBILITIES ................................................................................................................................................. 410. GUIDELINES: CODE OF CONDUCT FOR SUPPLIERS AND CONTRACTORS ..................................................... 4APPENDIX 1 - GUIDELINES: CODE OF CONDUCT FOR SUPPLIERS AND CONTRACTORS TO KEYWORDS STUDIOS AND
ALL GROUP COMPANIESCONFIDENTIAL AND PROPRIETARY - Proprietary notes apply. Printed documents are subject to change. Verify correct revision before use.
PROPRIETARY NOTE: This document contains information proprietary to Keywords Int’l. Any disclosure or use is expressly prohibited, except upon explicit written permission.

Document Title

Document No.

Version

GLB-HR-23-11-INT
Prevention of Modern Slavery Policy

0.3

Last Revision Date

Nov. 18, 23

Page 3 of 6

1. AIMS
Keywords Studios is opposed to slavery and human trafficking in any part of our activities or supply chain. We arecommitted to ensuring that we have appropriate policies and procedures in place to identify and prevent thesepractices.

2. SCOPE
The Prevention of Modern Slavery policy applies to all employees of Keywords (the “Group”).

3. REVIEW
The management team is responsible for the ongoing review of this document. This will be carried out annually oras and when organisational changes impact the way the group works. An amendment record will be maintained todocument the changes made in each new issue.

4. FEEDBACKFeedback regarding this document should be directed to any one of the department managers.

5. INTRODUCTION
At Keywords, we do not tolerate any form of modern slavery or human trafficking in any part of our business. We
operate to international standards and principles including the International Bill of Human Rights, the UN’s Guiding
Principles on Business and Human Rights, the International Labour Organization’s Declaration on Fundamental
Principles and Rights at Work and the Children’s Rights and Business Principles.
Keywords Studios and any of its subsidiary or associated companies acknowledges global responsibility and iscommitted to driving out acts of modern day slavery and human trafficking from within its own business and supply
chains. Keywords acknowledges its responsibility under relevant National Modern Slavery Acts and will ensuretransparency is achieved within the organisation to ensure that awareness of the Acts is achieved on a consistentbasis.
Keywords Studios will make reasonable endeavors to ensure all employees and agents within our supply chains are
not subject to any form of forced, compulsory/bonded labor or human trafficking. Adequate resources will bemade available to ensure slavery and human trafficking are not taking place within our organisation or, to the bestof our knowledge, within our supply chains.
This Statement and associated documentation will be reviewed annually.

6.

DEFINITION
Modern 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 aperson's liberty by another in order to exploit them for personal or commercial gain. People in these situations ofexploitation cannot refuse or leave because of threats, violence, coercion, deception, and/or abuse of power.
Forms of modern slavery:
••
•
•
•
•

Forced labor
Debt Bondage
Human Trafficking
Descent-based slavery
Child slavery
Forced and early marriage

CONFIDENTIAL AND PROPRIETARY - Proprietary notes apply. Printed documents are subject to change. Verify correct revision before use.
PROPRIETARY NOTE: This document contains information proprietary to Keywords Int’l. Any disclosure or use is expressly prohibited, except upon explicit written permission.

Document Title

Document No.

Version

GLB-HR-23-11-INT
Prevention of Modern Slavery Policy

0.3

Last Revision Date

Nov. 18, 23

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7. DUE DILIGENCE PROCESS AND MITIGATION RISK
As part of our efforts to identify and mitigate risk, we will assess our supply chains and our agency labourproviders. We will put in place systems to:•••••

Identify, assess and monitor potential risk areas in our supply chains
Mitigate the risk of slavery and human trafficking occurring in our supply chains
Drive best practices in tackling modern slavery and human trafficking
Protect whistleblowers through our Whistleblower (Protected Disclosure) Policy
Make available Code of Conduct to Suppliers and Contractors (See guidelines below)

8. FURTHER STEPS
Keywords is committed to maintaining high ethical standards, protecting human rights, and acting with honesty
and integrity in everything we do. We endeavor to understand where there are risks of modern slavery within any
part of our business and supply chain so that we can address them appropriately and sustainably.
We will continuously review our policies and develop key performance indicators (KPIs) to ensure that we aremeasuring how effective we have been to ensure that slavery and human trafficking is not taking place in any partof our business or supply chains.
Once a year, our policy is shared with our studio locations. We confirm at that time that all suppliers have signed
off on our policy and we secure documentation for audit purposes.

9. RESPONSIBILITIESThe Chief People and Culture Officer is responsible for implementing, maintaining and interpreting thisdocument.

10.GUIDELINES: CODE OF CONDUCT FOR SUPPLIERS AND CONTRACTORS
An approved supplier must adhere to the following provisions while providing services to Keywords Studios or anyof its subsidiary or associated companies:
1. Forced involuntary labor
Workers will not be subject to any forms of coercion. All work must be voluntary. Workers must have the rightto terminate their employment freely, as appropriate following a reasonable period ofnotice in accordance with applicable laws and collective agreements.
2. Document retention
Confiscating or withholding worker identity or other valuable items, including work permits and travel documents(e.g. passports) is strictly prohibited. The retention of personal documentation shall not be used as a means tobind workers to employment or to restrict their freedom of movement.
3. Humane treatment
The workplace shall be free from any form of harsh or inhumane treatment. Disciplinary policies and procedures
shall be clearly defined and communicated to all workers and shall not include any inhumane disciplinary
measures, including mental or physical coercion or verbal abuse of workers. Threats of physical or sexual
violence, harassment and intimidation against workers, their family and close associates are strictly prohibited.
4. Workers Equality
All workers shall be treated fairly and equitably. Workers shall be able to report grievances to their employers
about their treatment and conditions and they will not face retaliation for raising a grievance.
CONFIDENTIAL AND PROPRIETARY - Proprietary notes apply. Printed documents are subject to change. Verify correct revision before use.
PROPRIETARY NOTE: This document contains information proprietary to Keywords Int’l. Any disclosure or use is expressly prohibited, except upon explicit written permission.

Document Title

Document No.

Version

GLB-HR-23-11-INT
Prevention of Modern Slavery Policy

0.3

Last Revision Date

Nov. 18, 23

Page 5 of 6

5. Freedom of Movement and Personal freedoms
Workers’ freedom of movement shall not be unreasonably restricted. Workers shall not be physically confined tothe workplace or related premises nor shall any other means of coercion be used to restrict their freedom ofmovement or personal freedom.

CONFIDENTIAL AND PROPRIETARY - Proprietary notes apply. Printed documents are subject to change. Verify correct revision before use.
PROPRIETARY NOTE: This document contains information proprietary to Keywords Int’l. Any disclosure or use is expressly prohibited, except upon explicit written permission.

Document Title

Document No.

Version

GLB-HR-23-11-INT
Prevention of Modern Slavery Policy

0.3

Last Revision Date

Nov. 18, 23Page 6 of 6

APPENDIX 1
GUIDELINES: CODE OF CONDUCT FOR SUPPLIERS AND CONTRACTORS TO KEYWORDS STUDIOS AND ALL
GROUP COMPANIES
Keywords Studios is opposed to slavery and human trafficking in any part of our activities or supply chain. We arecommitted to ensuring that we have appropriate policies and procedures in place to identify and prevent thesepractices.
An approved supplier must adhere to the following provisions while providing services to Keywords Studios or anyof its subsidiary or associated companies:
1.

Forced involuntary labor

Workers will not be subject to any forms of coercion. All work must be voluntary.
2. Document retentionConfiscating or withholding worker identity or other valuable items, including work permits and travel documents(e.g. passports) is strictly prohibited. The retention of personal documentation shall not be used as a means tobind workers to employment or to restrict their freedom of movement.
3. Humane treatment
The workplace shall be free from any form of harsh or inhumane treatment. Disciplinary policies and procedures
shall be clearly defined and communicated to all workers and shall not include any inhumane disciplinary
measures, including mental or physical coercion or verbal abuse of workers. Threats of physical or sexual
violence, harassment and intimidation against workers, their family and close associates are strictly prohibited.
4. Workers Equality
All workers shall be treated fairly and equally.
5. Freedom of Movement and Personal freedoms
Workers’ freedom of movement shall not be unreasonably restricted. Workers shall not be physically confined to
the workplace or related premises nor shall any other means of coercion be used to restrict their freedom ofmovement or personal freedom.
We agree to abide by the above code of conduct
Supplier Name ___________________________________
Supplier Director _________________________________
Date ___________________________________________

CONFIDENTIAL AND PROPRIETARY - Proprietary notes apply. Printed documents are subject to change. Verify correct revision before use.
PROPRIETARY NOTE: This document contains information proprietary to Keywords Int’l. Any disclosure or use is expressly prohibited, except upon explicit written permission.