Policy Statement

Commitment to ensuring responsible business conduct

This Pragma and Associates Limited (we/our/the company) policy statement outlines our commitment to promoting and embedding responsible business conduct and transparency across all of our operations. It also sets out our expectations and requirements from staff, stakeholders, contractors and suppliers.

Our approach is in accordance with international and national standards, industry best practice, the United Nations Universal Declaration of Human Rights, the UK Modern Slavery Act 2015, and the Bribery Act 2010.

1. About this policy

This policy is governed by the board of directors. Risk assessments will be conducted, and the outcomes may shape our corporate risk process.

2. Responsibilities and expectations

Notwithstanding any separate policy documents we may have in force from time to time, we aim to uphold and expect all of our suppliers, employees, and partners to comply with the following principles, which are non-exhaustive (and, where applicable, have their own ethical processes in place to ensure the below are complied with):

• we expect our employees, suppliers, and business partners to act with integrity, demonstrate respect for others, and to uphold business practices aligned with international human rights standards and best practice.
• we aim to comply with national and international human rights laws and ensure that workers are treated with dignity, respect, and fairness. To this end, we try to ensure our suppliers comply with human rights laws and to respect human rights, as well as having mechanisms for due diligence, subcontracting, reports, record keeping and audits.
• we respect the rights of our communities wherever we operate.
• we oppose all forms of slavery, human trafficking, and forced or bonded labour. We will not tolerate any form of exploitation and require all suppliers to comply with the UK Modern Slavery Act 2015.
• we uphold the rights of children and will not engage in or support the use of child labour in any part of our business or supply chain. Our recruitment processes are designed to ensure that all workers are of legal working age in line with national laws.
• we are committed to providing a workplace free from discrimination (on any basis and in respect of any legally recognised protected characteristic). We promise diversity, equity, and inclusion and ensure equal opportunities for all employees.
• we are committed to carrying out appropriate due diligence measures, where necessary, to help identify and mitigate potential adverse concerns or impacts.
• we encourage all of our employees and stakeholders to speak up when breaches or violations of the law or this policy are found or suspected. Employees can report concerns to their direct line managers (or, if necessary, the next above in the reporting line).
• we are committed to selecting and doing business with suppliers or partners who can demonstrate that they operate in a manner consistent with our standards, commitments, and this policy. We also require them to ensure that their own business partners meet said standards.
• we are committed to taking necessary remedial action where we identify human rights, or other concerns which have arisen from or been caused by our actions.
• we have a zero tolerance approach to bribery, corruption, fraud, or unethical conduct.
• We will consider the environmental impact of internal processes and procedures.
• we report as needed and are completely transparent in respect of how we manage ESG risks.
• We will ensure that all employees, key stakeholders, and those responsible for implementing this policy are made aware of the company’s commitment to these principles and are provided with the tools and resources needed to uphold them.

3. Monitoring and compliance

We will regularly monitor and assess our practices to ensure compliance with this policy. Measures will include:

• reviewing our operations and supply chain to identify potential risks, as set out above.
• evaluating the effectiveness of our internal initiatives, including employee surveys and feedback to identify areas for improvement.
• where necessary and/or proportionate, we will engage independent third parties to conduct audits of our business practices, ensuring that our policies are being implemented effectively (this includes assessing supplier businesses).

4. Reporting and whistleblowing

We encourage all employees, suppliers, and stakeholders to report any concerns or potential violations of this policy to the board of directors, or (in the case of employees and where it is appropriate to do so) your line manager.

Reports can be made confidentially through any appropriate whistleblowing channels, and we guarantee that any such concerns will be treated with the upmost seriousness.

Retaliation or discrimination against those who raise complaints in good faith will not be tolerated and could lead to (in the case of employees) disciplinary action being taken.