Beranek Inc. Modern Slavery Act Policy
03/2020
This policy is made on behalf of Beranek Inc, in line with section 54(1) of the Modern Slavery Act 2015 ("MSA") and constitutes anti-slavery and human trafficking policy.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced or compulsory labor, human trafficking, child labor, all of which have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain. We have a zero-tolerance approach to any form of modern slavery, and we fully support the MSA principles. To that end, we've implemented and are enforcing systems and controls to ensure modern slavery is not taking place anywhere in our business or in our supply chain.
Our Business
Beranek, Inc. offers world-class manufacturing and high-precision machining capabilities for the Aerospace, Defense, and Space Exploration industries.
Code of Conduct
Beranek's core mission is to provide our customers with industry-leading expertise and unparalleled dedication to service in a manner consistent with the highest ethical business practices. As part of this process, we have in place an Anti-Slavery and Trafficking Policy ("MSA Policy") that seeks to identify and manage modern slavery risk in our business and supply chain.
In addition to our MSA Policy, we also have in place a Supplier Code of Conduct ("Supplier Code"), which helps us select business partners that follow workplace standards and business practices consistent with our own. Our goal is to partner with companies that embrace our core values and exemplify a genuine dedication to ethical and honest dealing. The Supplier Code sets forth the minimum standards of conduct expected of our business partners, including the need to maintain and enforce procedures designed to prohibit the use of forced, compulsory, or trafficked labor, or anyone held in slavery or servitude, whether adults or children. The Supplier Code applies to all persons and entities that provide goods or services to Beranek, Inc. and its Customers, including, but not limited to, suppliers, subcontractors, vendors, and consultants (collectively, "Suppliers").
Beranek, Inc. requires all Suppliers and their employees to commit to the Supplier Code as a condition of doing business. All Suppliers must also operate in full compliance with the letter and spirit of all applicable laws and regulations, including all laws relating to slavery and human trafficking.
Our Organizations' Structure
Beranek, Inc. operates under the direction of a President and Vice-President top executives, with Administration, Manufacturing Operations, Quality, and support structure. Suppliers are relied upon within all aspects of the business.
Supply Chain
Our supply chain consists of suppliers. Throughout our history, Beranek, Inc. has recognized the value in fostering relationships with the trade community, working with reliable and reputable firms that share our values.
To work with Beranek, Inc., suppliers must demonstrate that they are viable, productive companies and agree to adhere to our Supplier Code. They must also complete our Supply Chain Pre-Qualification Package, which includes our pre-qualification survey, terms and conditions, and health and safety responsibilities.
Risk Assessment
Beranek, Inc. expects all relevant supply chain members to comply with the Modern Slavery Act 2015.
The highest risk of slavery and human trafficking within our supply chain will likely stem from Supplier's personnel and our raw material suppliers' workforce, mainly based in high-risk countries. Given our business's scope, we know the risks of slavery and human trafficking in specific markets, where workers can be trafficked, exploited, and forced to work. To mitigate these risks, we consider the risk of slavery and human trafficking in selecting any new raw material suppliers.
A risk assessment has been carried out focusing on smaller businesses that must not have their own Modern Slavery Act statement. This risk assessment will continue to be updated as and when new suppliers enter our supply chain.
Due Diligence
As part of our initiative to identify and manage modern slavery risk, Beranek, Inc. has implemented the following:
An Anti-Slavery and Human Trafficking Policy that reflects our commitment to respecting human rights everywhere we operate and to ensure there is no modern slavery or human trafficking in any aspect of our business.
A Supplier Code, to help us work only with companies that embrace our core values and share our zero-tolerance approach to modern slavery
An enhanced system for supply chain pre-qualification, including adding modern slavery inquiries to our standard form pre-qualification questionnaire.
A supply chain review for the identification of any high-risk suppliers and jurisdictions.
Monitoring and Reporting
Beranek, Inc's responsibility for preventing, detecting, and reporting modern slavery in our business is a priority.
Employees with concerns about modern slavery taking place at Beranek, Inc, or any of or suppliers or Supplier sub-tiers must report immediately to their managers, company executives, or Human Resources department.
Training
Training for Beranek, Inc. Code of Ethics & Business Conduct has been completed. It enforces our employees' obligation to follow applicable laws, report concerns of illegal or unethical activities. Beranek's employees have signed the acknowledgment on the content, procedures, and their agreement to comply.
Responsibility for This Statement
Beranek, Inc. Top Management has overall responsibility for ensuring this policy and the MSA Policy comply with our legal and ethical obligations and that Beranek, Inc. employees comply with them.
Beranek, Inc. Top Management approved this statement on March 30, 2020. This policy will be reviewed annually in the Management Review Meeting and published on Beranek, Inc. website.