Back1. Introduction
Creek & Pine (legal: Supernormal d.o.o, Sveti Petar Orehovec 67, 48267 Orehovec, Croatia, VAT number HR18965816268) is committed to ensuring that our business operations and supply chains are free from human trafficking and modern slavery. This policy outlines our stance against these crimes and the steps we take to prevent, identify, and address any such activities within our organization and supply chains.
2. Purpose
The purpose of this policy is to:
- Demonstrate our commitment to ethical business practices and the protection of human rights.
- Comply with all relevant laws and regulations related to human trafficking and modern slavery.
- Establish a framework for identifying and addressing risks related to human trafficking and modern slavery.
3. Scope
This policy applies to all employees, officers, directors, contractors, consultants, suppliers, and any other individuals or entities representing Creek & Pine (collectively referred to as “employees”).
4. Definitions
- Human Trafficking: The recruitment, transportation, transfer, harboring, or receipt of persons by means of threat, force, coercion, abduction, fraud, deception, abuse of power, or payment to achieve the consent of a person for the purpose of exploitation.
- Modern Slavery: Practices such as slavery, servitude, forced or compulsory labor, and human trafficking.
5. Commitment
Creek & Pine is committed to:
- Operating our business and supply chains free from human trafficking and modern slavery.
- Implementing and enforcing effective systems and controls to prevent human trafficking and modern slavery.
- Complying with all applicable laws and regulations related to human trafficking and modern slavery.
6. Risk Assessment and Due Diligence
- Conduct regular risk assessments to identify and evaluate the risk of human trafficking and modern slavery in our operations and supply chains.
- Perform due diligence on suppliers and contractors to ensure they adhere to our standards and legal requirements related to human trafficking and modern slavery.
- Require suppliers and contractors to confirm that they do not engage in human trafficking or modern slavery and have measures in place to prevent such practices.
7. Training and Awareness
- Provide training to employees on human trafficking and modern slavery to raise awareness and promote understanding of these issues.
- Ensure employees understand their role in preventing, identifying, and reporting potential cases of human trafficking and modern slavery.
8. Reporting and Whistleblowing
- Encourage employees and other stakeholders to report any concerns or suspicions related to human trafficking and modern slavery.
- Provide a confidential and anonymous reporting mechanism for whistleblowers.
- Protect whistleblowers from retaliation or adverse consequences for reporting concerns in good faith.
9. Investigation and Response
- Investigate any reported concerns or suspicions of human trafficking and modern slavery promptly and thoroughly.
- Take appropriate action against individuals or entities found to be engaged in human trafficking or modern slavery, including termination of contracts and reporting to relevant authorities.
10. Continuous Improvement
- Regularly review and update this policy to reflect changes in laws, regulations, and best practices.
- Continuously improve our systems and processes to better prevent, identify, and address human trafficking and modern slavery.
11. Compliance
- Ensure compliance with all applicable laws and regulations related to human trafficking and modern slavery, including but not limited to the Modern Slavery Act 2015 (UK), the Trafficking Victims Protection Act (USA), and relevant EU directives.
- Require suppliers and contractors to comply with this policy and relevant laws and regulations.
12. Contact Information
For questions, concerns, or to report a violation, please contact the Human Rights Committee at hi@creekandpine.co.
Approved by: Vedran Židanik, CEO
Date: October 10, 2023