Modern Slavery Policy

SCOPE

This policy is applicable to all employees addressed at Pacer and it’s affiliates (together and individually, the “Company”).

POLICY STATEMENT

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, and suppliers. Pacer strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organization or in any of our supply chains

MODERN SLAVERY AND HUMAN TRAFFICKING

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

COMMITMENTS

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

  • We have a zero-tolerance approach to modern slavery in our organization and our supply chains.
  1. The prevention, detection and reporting of modern slavery in any part of our organization or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
  2. We are committed to engaging with our stakeholders to address the risk of modern slavery in our operations and supply chain.
  3. We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risk-based approach, we will also assess the merits of writing to contractors requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
  4. As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits for compliance with our Code of Conduct.
  5. If we find that other individuals or organizations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.
  • In all our practices, Pacer shall not:
  1. Require Personnel to pay fees, charges, expenses or financial obligations incurred in order for the Personnel to secure their employment or placement (Recruitment Fees), regardless of the manner, timing or location of the imposition or collection of these Recruitment Fees.
  2. Share the travel or identity documents of Personnel provided for the sole purpose of recruitment opportunity by the personnel.
  3. Ensure Personnel can access a Grievance Mechanism to safely report any instances of Modern Slavery in the operations and supply chains used by the Supplier and can reach out to Grievance Officer at Compliance@pacerhcs.com.
  • We ensure that all our employees and Partners have suitable training about Modern Slavery and prepare a Modern Slavery Risk Management Plan.
  • We take all reasonable action to address or remove these practices, including where relevant by addressing any practices of other entities in its supply chains; and take all reasonable steps to remediate any adverse impacts caused or contributed to by the Supplier from these practices in accordance with the Guiding Principles on Business and Human Rights.
  • We follow Guiding Principles on Business and Human Rights as per UN framework as per the link below. https://www.ohchr.org/documents/publications/guidingprinciplesbusinesshren.pdf

CORPORATE GOVERNANCE

We will continue to review our policies and procedures to ensure that we have sound governance processes in place to meet our modern slavery compliance requirements. We will conduct reviews of policies, such as, our Code of Conduct and Whistleblower, to ensure inclusion of modern slavery clauses to increase employee awareness of the risks of modern slavery in our business and our supply chain.

PROTECTION & SUPPORT

  • We aim to encourage openness and will support all Individuals who raise genuine concerns under this policy, even if they turn out to be mistaken.
  • Any Individual must not suffer any detrimental treatment as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform HR Department at [If the matter is not remedied you should raise it formally using our Grievance Procedure.]