Company: Cleva Technologies, LLC
Responsible Officer: Larry Canipe
1. Purpose and Commitment
Modern slavery, including slavery, servitude, forced labor, and human trafficking, is a crime and a gross violation of fundamental human rights. Cleva Technologies, LLC maintains a zero-tolerance policy toward all forms of modern slavery. We are committed to acting with integrity in all business dealings and relationships and to implementing robust systems to prevent, detect, and remediate slavery and human trafficking across our operations and supply chains.
2. Scope of the Policy
This policy applies to:
- All employees of Cleva Technologies, LLC (full-time, part-time, temporary)
- Board members, officers, and executives
- Contractors, suppliers, distributors, and third-party service providers
- Agents, interns, and volunteers
- Any other individuals or entities acting on behalf of Cleva Technologies, LLC
3. Our Responsibilities
Cleva Technologies, LLC is responsible for ensuring this policy aligns with relevant legal obligations and ethical expectations, including but not limited to:
- UK Modern Slavery Act 2015
- Australia’s Modern Slavery Act 2018
- California Transparency in Supply Chains Act
- Other applicable regional or national anti-trafficking laws where we operate
We commit to:
- Reviewing our internal procedures and supply chains to assess and address potential modern slavery risks.
- Conducting due diligence on new suppliers and partners, with enhanced vetting for high-risk geographies or industries.
- Including specific anti-slavery clauses in contracts with suppliers and contractors.
- Taking remedial actions when violations or risks are identified.
4. Roles and Responsibilities
Company Management
Senior leadership, under the direction of Larry Canipe, is responsible for the implementation and ongoing review of this policy. They must:
- Ensure that internal controls and procurement practices align with this policy.
- Investigate any reports of violations thoroughly and confidentially.
- Monitor evolving legal obligations and update the policy as required.
Managers and Supervisors
All managers must:
- Communicate the policy to their teams and partners.
- Ensure team members understand their responsibilities through ongoing training and discussion.
- Foster a culture of compliance and openness.
Employees and Stakeholders
Every individual working for or with Cleva Technologies, LLC is expected to:
- Read, understand, and comply with this policy.
- Remain vigilant for signs of forced labor or trafficking in the business or supply chain.
- Report any suspicions or incidents immediately through appropriate channels.
5. Reporting Concerns
We encourage all employees, contractors, and stakeholders to report any concerns related to modern slavery. Reports can be made confidentially to:
- Your immediate manager
- A company director
- The responsible officer, Larry Canipe
We are committed to protecting whistleblowers who report concerns in good faith from retaliation, discrimination, or disciplinary action.
6. Enforcement and Consequences
Any violation of this policy by employees may result in disciplinary action, up to and including termination of employment. Contractors or third parties found in breach of this policy may have their contracts terminated immediately.
7. Training and Awareness
- Anti-slavery training is part of Cleva Technologies’ onboarding process for all new hires.
- Periodic refresher sessions will be conducted for all employees, with specific training for procurement and supplier management roles.
- Updates and reminders about this policy will be shared through internal communications.
8. Supplier and Partner Expectations
We require our suppliers, vendors, and contractors to:
- Comply with this Anti-Slavery Policy and applicable laws.
- Include similar anti-slavery provisions in their own supply chains.
- Cooperate with any audits or due diligence processes conducted by Cleva Technologies, LLC.
Where risks are identified, we will work constructively with suppliers to remediate practices. In cases of non-cooperation or serious violations, we will terminate the relationship.
9. Policy Review and Updates
This policy will be reviewed annually or as required due to changes in legal or operational circumstances. Feedback and suggestions for improvement are welcome and can be directed to Larry Canipe.
Approved by:
Larry Canipe
Managing Partner, Cleva Technologies, LLC