Policy Against Human Trafficking

Purpose

Alcohol Monitoring Systems Ltd (DBA SCRAM Systems®) is committed to a work environment that is free from human trafficking and slavery, which for purposes of this policy, includes forced labor and unlawful child labor. SCRAM Systems will not tolerate or condone human trafficking or slavery in any part of our global organization. This policy is consistent with SCRAM Systems’ Code of Ethics and Business Conduct and our core values to protect and advance human dignity and human rights in our global business practices.

SCRAM Systems employees, contractors, subcontractors, vendors, suppliers, partners, and others through whom SCRAM Systems conducts business must avoid complicity in any practice that constitutes trafficking in persons or slavery.

Scope

This Policy applies to all personnel employed by or engaged to provide services to SCRAM Systems, including, but not limited to, SCRAM Systems’s employees, officers, temporary employees, contingent workers (including agency workers), casual staff, and independent contractors (for ease of reference throughout this Policy, “employees”). Every SCRAM Systems employee is responsible for reading, understanding, and complying with this Policy.

SCRAM Systems managers are responsible for ensuring that employees who report to them, directly or indirectly, comply with this Policy and complete any certification or training required of them. If you have any questions or concerns relating to this Policy or learn of any violations, consult the SCRAM Systems Human Resources Department

Policy Statement

SCRAM Systems prohibits trafficking in persons and slavery. SCRAM Systems employees, contractors, subcontractors, vendors, suppliers, partners, and others through whom SCRAM Systems conducts business must not engage in any practice that constitutes trafficking in persons or slavery. This includes, but is not limited to, the following activities:

• Engaging in any form of trafficking in persons;
• Procuring commercial sex acts;
• Using forced labor in the performance of any work;
• Destroying, concealing, confiscating, or otherwise denying access by an individual to the individual’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority;
• Using misleading or fraudulent practices during the recruitment of candidates or offering of employment/contract positions; such as failing to disclose, in a format and language accessible to the potential candidate, basic information or making material misrepresentations during the recruitment of candidates regarding the key terms and conditions, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs(if provided by SCRAM Systems), any significant cost to be charged to the candidate, and, if applicable, the hazardous nature of the work;
• Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
• Charging applicants/candidates recruitment fees;
• If required by law or contract, failing to provide return transportation or failing to pay for the cost of return transportation upon the end of employment;
• If required by law or contract, failing to provide or arrange housing that meets the host country’s housing and safety standards; or
• If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work documents in writing.

SCRAM Systems is committed to maintaining and improving its systems and processes to eradicate human trafficking and slavery in its direct hardware supply chain. SCRAM Systems will not tolerate retaliation against an employee for reporting a concern in good faith or for cooperating with a compliance investigation, even when no evidence is found to substantiate the report.

Any violation of this Policy may be grounds for disciplinary action, up to and including termination, subject to applicable law. Violation of applicable laws may also result in criminal prosecution of responsible individuals.