1.    Introduction

The Underwriting Exchange AG is committed to preventing and combating modern slavery in all its forms. As a responsible business, we have developed this Modern Slavery Policy to demonstrate our commitment to human rights, ethical practices, and the eradication of modern slavery from our operations and supply chains. This policy outlines our zero-tolerance approach to modern slavery and provides a framework for our employees and business partners to identify, report, and mitigate any risks.

2.    Policy Statement:

  1. We condemn all forms of modern slavery, including forced labor, human trafficking, child labour, and debt bondage.
  2. We are committed to upholding and promoting human rights, dignity, and fair treatment for all individuals.

3.    Compliance with Applicable Laws

  1. We comply with all relevant laws and regulations pertaining to modern slavery, including but not limited to the Modern Slavery Act [insert applicable legislation].
  2. We also expect our business partners and suppliers to comply with applicable laws and demonstrate a commitment to eradicating modern slavery from their operations.

4.    Risk Assessment

  1. We conduct regular risk assessments to identify and understand the potential modern slavery risks within our operations and supply chains.
  2. The risk assessment considers factors such as geographical locations, industries, subcontracting practices, and workforce demographics.

5.    Supply Chain Due Diligence

  1. We implement robust due diligence procedures to assess and monitor our supply chains, identifying potential risks of modern slavery.
  2. We engage with suppliers and business partners to ensure they share our commitment to eradicating modern slavery and promote ethical labor practices.

6.    Supplier Engagement and Contracts

  1. We communicate our expectations regarding modern slavery to our suppliers and business partners, including the requirement to comply with applicable laws and regulations.
  2. We include contractual provisions that explicitly prohibit the use of modern slavery in any form within our supply chains.

7.    6. Employee Awareness and Training

  1. We provide training and resources to our employees to raise awareness about modern slavery and empower them to identify and report any suspicions or concerns.
  2. We maintain an open and supportive environment for reporting, ensuring confidentiality and protection for whistleblowers.

8.    Reporting and Investigation

  1. We encourage the reporting of any suspected instances of modern slavery through established reporting channels.
  2. All reports will be treated confidentially and investigated promptly and thoroughly. Appropriate action will be taken in response to substantiated cases.

9.    8. Continuous Improvement

  1. We regularly review and update our Modern Slavery Policy to ensure its effectiveness and alignment with evolving best practices and legislation.
  2. We actively engage with stakeholders, industry initiatives, and civil society organizations to stay informed and collaborate on combating modern slavery.

By implementing this Modern Slavery Policy, we demonstrate our commitment to ethical business practices, human rights, and the eradication of modern slavery. All employees are expected to comply with this policy, and any violations may result in disciplinary action, up to and including termination.

Version:                                    1.0

Date Adopted:             22.06.2023