Anti-Slavery and Human Trafficking Policy

Published date: 16th May 2018

ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY

Introduction

Nettitude is committed to preventing slavery and human trafficking occurring in any of its corporate
activities, as well as seeking to ensure that our supply chains are also free from such practices.
Our organisational structure and operations
Nettitude is a provider of IT Consultancy and Cyber Security Services working in the IT Security
Services Sector. Nettitude employ 125 people worldwide and operate in
• USA
• Europe
• Asia
• Middle East

Nettitude is a 100% focused Cyber Security Consultancy and is recognised as a leader within its
field. Nettitude is a privately owned company, established in 2003. Its EMEA head office (Nettitude Ltd)
is based in Warwickshire, UK and its North American head office (Nettitude Inc) is located in Manhattan,
New York.

Nettitude is a member of CREST and holds the strongest certifications within the Penetration Testing
sector. Nettitude has been delivering penetration testing for more than 14 years and has a large team
of certified and registered CREST testers. Nettitude conducts traditional infrastructure, web application,
social engineering and wireless testing engagements as well as more specialised Mobile, SCADA, IoT
and Red Teaming skills. Nettitude delivers advanced testing under CBEST and STAR with custom written
malware implants and command & control frameworks.
Nettitude has a team of Threat Intelligence Analysts and Incident Response Consultants covering all
levels and specialisations of cyber offensive and defence activities. Our N-CERT team manages and
deals with incidents at all levels on a daily basis. This includes in-depth network based packet analysis,
malware and reverse engineering along with host based intrusion investigations. Our Research and
Innovation team finds and reports vulnerabilities, writes exploit code as well as developing our own
tools in house.

Nettitude has a SOC providing 24 x 7 x 365 assurance for our clients in the following ways: SOC
Manage is able to design, implement, monitor, manage and update security technology within our
client environments; SOC Monitor provides you with assurance that your environment is not only being
monitored but that alerts and an appropriate response can be determined quickly when needed. SOC
Scanning provides a comprehensive Continuous Vulnerability Scanning service, using leading edge
technology deployed by security professionals to scan your assets and report known vulnerabilities
removing the burden from your security team.

Policies relating to slavery and human trafficking

Our statement reflects our commitment implementing and enforcing effective procedures and controls
to minimise the risks of human trafficking and other modern slavery practices infiltrating our business
operations or supply chains, [and to acting ethically and with integrity in all our business activities and
relationships].
We ensure that our associates are aware of our policies [and take appropriate measures to ensure
that our associates adhere to the same high standards].
Staff training/induction
During induction we ensure that staff fully understand the risks of modern slavery and human
trafficking infiltrating our business and effectively operate our policies and procedures aimed at
mitigating this risk.
We make specific provision in our whistleblowing policy for the protection of those who whistle-blow
in relation to an issue of modern slavery.

1. POLICY STATEMENT

1.1 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 a person’s liberty by another in order to exploit them for personal or commercial gain.
We have 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 supply chains.

1.2 We are also committed to ensuring there is transparency in our own business and in our approach
to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations
under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors,
suppliers and other business partners, and as part of our contracting processes, we include specific
prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or
servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to
the same high standards.

1.3 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, interns, agents,
contractors, external consultants, third-party representatives and business partners.

1.4 This policy does not form part of any employee’s contract of employment and we may amend it at
any time.

2. RESPONSIBILITY FOR THE POLICY

2.1 The board of directors has overall responsibility for ensuring this policy complies with our legal
and ethical obligations, and that all those under our control comply with it.

2.2 The HR department has primary and day-to-day responsibility for implementing this policy,
monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control
systems and procedures to ensure they are effective in countering modern slavery.

2.3 Management at all levels are responsible for ensuring those reporting to them understand and
comply with this policy and are given adequate and regular training on it and the issue of modern
slavery in supply chains.

3. COMPLIANCE WITH THE POLICY

3.1 You must ensure that you read, understand and comply with this policy.

3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply

chains is 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.

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

3.4 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.

3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify
your manager or report it in accordance with our Whistleblowing Policy as soon as possible.

3.6 If you are unsure about whether a particular act, the treatment of workers more generally, or their
working conditions within any tier of our supply chains constitutes any of the various forms of modern
slavery, raise it with your manager or the compliance officer.

3.7 We aim to encourage openness and will support anyone who raises genuine concerns in good faith
under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers
any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of
whatever form is or may be taking place in any part of our own business or in any of our supply chains.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment
connected with raising a concern. If you believe that you have suffered any such treatment, you should
inform the compliance manager immediately. If the matter is not remedied, and you are an employee,
you should raise it formally using our Grievance Procedure.

5. BREACHES OF THIS POLICY

5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal
for misconduct or gross misconduct.

5.2 We may terminate our relationship with other individuals and organisations working on our behalf
if they breach this policy.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the
steps we have taken to ensure that our business as well as our supply chains are free from slavery
and human trafficking during the financial year ending April 2018.