Modern Slavery Policy

This Policy 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. GreenRoad takes this matter of the upmost importance, ensuring the highest levels of compliance with our business and that of our suppliers.

Introduction
GreenRoad is committed to preventing slavery and human trafficking occurring in any of its activities, as well as seeking to ensure that our supply chains are also free from such practices.

Our organisational structure and operations                                                                                                          

GreenRoad is a provider of hardware, software, and Mobile Applications to customers whose businesses involve vehicle operations where there is a requirement to track these assets and to improve safe vehicle operations across the orgnaisaiton.

We employ approximately 100 people worldwide. We operate primarily from the United Kingdom, the United States of America, Australia and Holon.  Our customers use – and we support – our products and services in their vehicle fleets throughout the world.

Nature of our supply chains
Our key supply chains involve electrical hardware manufacturing in the Far East, with sub-assembly in the United Kingdom, the United States of America and Holon. In addition, we use a variety of suppliers to provide vehicle installation services, IT services and legal services.

Risk assessment and due diligence
GreenRoad has reviewed, and continues to review, the risks that these supply chains can present and will seek to continually review the operations of existing suppliers in relation to the risk of modern slavery and human trafficking.  GreenRoad does this by asking our suppliers to complete a supplier questionnaire detailing our corporate social responsibility requirements, to which all suppliers must conform. We perform due diligence at the start of every business relationship.

We expect our suppliers and contractors to demonstrate a zero-tolerance approach to exploitation. To this end, all new contracts, and those renewing, include a clause requiring that our suppliers, and their subcontractors, comply with the Act, and include GreenRoad’s right to terminate in the instance of any breach of this obligation.

As part of our procurement process, we engage only with suppliers and contractors who confirm their compliance with the Act. This is a start-up obligation that is cross-checked for conformance. GreenRoad considers our exposure to modern slavery to be limited. We monitor and manage the risk of our supply chain by pre-appraising new vendors and continually monitoring existing vendors. We use a relatively stable number of suppliers, most of which we have developed long-term relationships with. We seek specific assurances from suppliers that are most exposed to risk.

We are committed to implementing and enforcing effective procedures and controls to minimize the risk 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 expect our employees to fully comply with the Modern Slavery Act 2015 and our associated procedures. Any non-compliance would result in facing disciplinary procedures. No incidents of non-compliance with applicable laws and policies have currently been reported to date.

Staff training
We provide periodic training to key staff to ensure that they understand the risks of modern slavery and human trafficking infiltrating our business or supply chains and effectively operate our policies and procedures aimed at mitigating this risk.

Future action
During 2021, we plan to:

• Continue auditing our key suppliers to ensure their compliance with corporate social responsibilities and legislation
• Support our ‘whistle blowing’ policy to ensure a transparent approach for reporting any non-compliant incidents
• Continue to conduct awareness training for staff who are at risk of encountering modern slavery situations to assist in identification and reporting of any suspicious incidents