Modern Slavery Statement

Introduction

This statement sets out Redwood’s actions to understand and minimize all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 2023.

Redwood recognizes that it has a responsibility to take a robust approach to slavery and human trafficking and is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organizational Structure and Supply chains

Redwood Software operates in business and IT process automation, providing a suite of automation capabilities, global reach, and a 24/7 customer success network. Through acquisitions led by Turn/River, today Redwood’s solutions include RunMyJobs, ActiveBatch, JSCAPE’s managed file transfer (MFT) platform, Cerberus’s secure file transfer, and Tidal Software.

The organization currently operates in the following countries:

Redwood has business relationships based predominantly within Europe and the USA.

The software business sector is not considered one most ‘at risk’ and no Redwood subsidiary company has intricate supply chains (or partnerships) with businesses based in impoverished regions of the world, where labor laws are non-existent or are not enforced.

Our commitment to the principles of the Modern Slavery Act 2015.

Redwood is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking.

As an equal opportunities’ employer, we’re committed to creating and ensuring a non-discriminatory and respectful working environment for our employees. We want all our employees to feel confident that they can expose wrongdoing without any risk to themselves.

Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in their respective location and to safeguard employees from any abuse or coercion.

Embedding the Principles

We will continue to embed the principles through:

Policy

The Anti-slavery and Human Trafficking Policy is available to all employees at Redwood and will be reviewed by Redwood’s Chief People Officer annually to ensure compliance.

All employees and direct contractors are contractually obliged to comply with Redwood’s policies, which includes the modern slavery prevention policy.

Risk Assessments

Redwood will conduct effective due diligence with all new suppliers and audit all relevant existing suppliers to ensure that business operations are free from involvement with slavery and human trafficking.

Mandatory Training

Redwood provides e-learning training courses for employees involved in HR and the wider supply chain (training is also available to all other employees), which covers:

• Awareness as to the various forms of modern slavery in which people can be held and exploited.
• How employees can identify the signs of slavery and human slavery.
• How employees should respond if they suspect slavery or human trafficking.

Our Policies in relation to the Modern Slavery Act 2015

Redwood operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Code of Conduct. The organization’s code makes clear to employees the actions and behavior expected of them when representing the organization. The organization strives to maintain the highest standards of employee conduct and ethical behavior when operating abroad and managing its supply chain.
• Whistleblowing Policy. The organization encourages all its workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of the organization. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organization’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
• Bullying and Harassment Policy. The organization encourages all its workers, customers, and other business partners to treat each other with the utmost respect. The organization deplores all forms of bullying and harassment, which will not be tolerated under any circumstances.
• Diversity and Inclusion Policy. The organization is committed to and encourages all its workers, customers, and other business parents to apply equality of opportunity, diversity and to provide a service following practices which are free from unfair and unlawful discrimination.
• Recruitment and Selection Policy. The organization uses only specified, reputable employment agencies to source labor and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due Diligence

The organization undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organization’s due diligence and reviews include:

• Mapping the supply chain broadly to assess product or geographical risks of modern slavery and human trafficking. Evaluating the modern slavery and human trafficking risks of each new supplier.
• Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.
• Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance Indicators

The organization has reviewed its key performance indicators (KPIs) with consideration of the Modern Slavery Act 2015. As a result, the organization is:

• Requiring all relevant staff to have completed e-learning training on modern slavery.
• Developing a system for supply chain verification whereby the organization evaluates potential suppliers before they enter the supply chain.
• Reviewing its existing supply chains, whereby the organization evaluates all relevant existing suppliers.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

This statement has been approved by the organization’s Chief People Officer, who will review and update it annually.

Last updated: August 2023.