ÁñÁ«ÊÓÆµ

Intro

ÁñÁ«ÊÓÆµ and its affiliated companies (collectively “ÁñÁ«ÊÓÆµâ€) are committed to good corporate citizenship and conducting business in a manner consistent with the highest ethical standards.  To that end, ÁñÁ«ÊÓÆµ maintains policies and internal systems designed to prevent the potential use of any form of Slave Labor or Human Trafficking by its businesses, employees, contractors, and third-party suppliers.

ÁñÁ«ÊÓÆµ implements these and other related measures in a manner consistent with its obligations under the California Transparency in Supply Chains Act and the United Kingdom Slavery Act, respectively.  Copies of ÁñÁ«ÊÓÆµâ€™ official statements under these laws are available at the following links:

California Transparency in Supply Chains Act Statement

Introduction

ÁñÁ«ÊÓÆµ and its affiliated companies (collectively “ÁñÁ«ÊÓÆµâ€) are committed to good corporate citizenship and conducting business in a manner consistent with the highest ethical standards.  To that end, ÁñÁ«ÊÓÆµ strictly prohibits its businesses, employees, contractors, and suppliers from engaging in any form of Slave Labor or Human Trafficking.  ÁñÁ«ÊÓÆµ will also take proactive and reasonable steps to identify and eliminate the use of Slave Labor and Human Trafficking from its global supply chain whenever possible.

ÁñÁ«ÊÓÆµ makes this statement Statement (“Statementâ€) pursuant to the 2015 California Transparency in Supply Chains Act (“CTSCAâ€).  It covers ÁñÁ«ÊÓÆµâ€™ activities for the prior fiscal year (FY2022) and applies to all ÁñÁ«ÊÓÆµ employees, officers, directors, agents, consultants, and any other persons acting on behalf of any entity owned or controlled by ÁñÁ«ÊÓÆµ (“ÁñÁ«ÊÓÆµ Personnelâ€) anywhere in the world.  Where applicable, this Statement also addresses ÁñÁ«ÊÓÆµâ€™ ongoing efforts to comply with the U.S. Uyghur Forced Labor Prevention Act (“UFPLAâ€), the United Kingdom Modern Slavery Act 2015 (“Modern Slavery Actâ€), and anti-slavery standards published by the International Labor Organization (“ILOâ€) (collectively “Anti-Slavery Lawsâ€).

Supply Chain Verification

ÁñÁ«ÊÓÆµ is committed to promoting human rights and fair treatment for all persons.  With these values in mind, ÁñÁ«ÊÓÆµ strictly prohibit all forms of Slave Labor identified under the Modern Slavery Act and other applicable anti-slavery laws.  Notable examples include, without limitation, bonded labor, child labor, forced labor, prison labor, and other forms of indentured servitude.  ÁñÁ«ÊÓÆµ also prohibits any form of Human Trafficking, including the transportation, harboring, recruitment, transfer, or receipt of persons by means of threat, fraud, force, exploitation, coercion, or abduction.  These prohibitions extend to all ÁñÁ«ÊÓÆµ Personnel regardless of their location, nationality, or role within the enterprise.

In addition to overseeing its own activities, ÁñÁ«ÊÓÆµ also has zero tolerance for any use of Slavery or Human Trafficking by its agents, consultants, contractors, and other third-party suppliers and vendors (“Third Party Suppliersâ€).  We expect that all Third Party Suppliers will comply with applicable wage and labor laws in the countries where they operate, and will meet internationally-recognized ILO standards in those instances where local and national laws may prove deficient.  Consistent with this zero tolerance policy, the company encourages any ÁñÁ«ÊÓÆµ Personnel who reasonably suspect potential non-compliance by Third Party Suppliers to notify their managers or ÁñÁ«ÊÓÆµâ€™ Legal Department consistent with the company’s Whistleblower Policy.

Supplier Audits

As a Hospitality Management Platform company, ÁñÁ«ÊÓÆµ does not rely on foreign products, materials, or components.  ÁñÁ«ÊÓÆµ currently has no international supply chains and does not currently deal in any of the sectors commonly associated with forced labor, human trafficking, and other forms of indentured servitude.  ÁñÁ«ÊÓÆµ also has limited exposure to the countries appearing in the 2023 Global Slavery Index published by Walk Free, a leading non-governmental organization specializing in combatting forced labor and human trafficking.1  To the extent that ÁñÁ«ÊÓÆµ hires employees or engages Third Party Personnel from the high-risk jurisdictions appearing in the Global Slavery Index, it typically does so pursuant to robust labor and employment laws administered by governments in North America, Western Europe, and other jurisdictions where Slavery and Human Trafficking are comparatively rare.

It is also important to note that the Hospitality Management Platform industry involves a highly skilled, highly mobile workforce where employees typically benefit from high demand for their services, and, by extension, higher wages.  This is particularly true for ÁñÁ«ÊÓÆµ, which provides specialized Hospitality Management Platform systems, software, and services to hotels and other similar establishments.  Although some these third-party customers could theoretically experience elevated exposure to domestic Anti-Slavery Laws given the nature of their business, there is currently no reason to suspect that these third-party risks would implicate, much less adversely affect, ÁñÁ«ÊÓÆµâ€™ own operations. Working from this basis, ÁñÁ«ÊÓÆµ currently has no information indicating that it or its Third Party Suppliers engage in any activities contrary to the CTSCA or other applicable Anti-Slavery Laws.

Supplier Certifications

Although the use of Slavery and Human Trafficking is comparatively rare in the Hospitality Management Platform sector, ÁñÁ«ÊÓÆµ reserves the right to terminate Third Party Suppliers that engage in any form of Slavery or Human Trafficking.  ÁñÁ«ÊÓÆµ also plans to seek the right to audit compliance with these standards as part of our Third Party Supplier onboarding process.  In those instances where Third Party Suppliers may pose potential Slavery or Human Trafficking risks, ÁñÁ«ÊÓÆµ may also conduct its own independent investigations in their activities and request certifications attesting to their compliance with the Modern Slavery Act and other applicable Anti-Slavery Laws. 

Internal Accountability & Employee Training

ÁñÁ«ÊÓÆµ is committed to conducting business with honesty and integrity.  To that end, any ÁñÁ«ÊÓÆµ Personnel who observe any potential or actual violations of the Modern Slavery Act or other applicable Anti-Slavery Laws are encouraged to contact their Managers or the company’s Legal Department in a manner consistent with ÁñÁ«ÊÓÆµâ€™ Whistleblower Policy.  The company does not permit any form of retaliation against ÁñÁ«ÊÓÆµ Personnel who report suspected violations of any Anti-Slavery Laws or related company policies in good faith.  

United Kingdom Supplier Transparency Statement

Introduction

ÁñÁ«ÊÓÆµ and its affiliated companies (collectively “ÁñÁ«ÊÓÆµâ€) are committed to good corporate citizenship and conducting business in a manner consistent with the highest ethical standards.  To that end, ÁñÁ«ÊÓÆµ strictly prohibits its businesses, employees, contractors, and suppliers from engaging in any form of Slave Labor or Human Trafficking.  ÁñÁ«ÊÓÆµ will also take proactive and reasonable steps to identify and eliminate the use of Slave Labor and Human Trafficking from its global supply chain whenever possible.

ÁñÁ«ÊÓÆµ makes this Slavery and Human Trafficking Statement (“Statementâ€) pursuant to Section 54 of the United Kingdom Modern Slavery Act 2015 (“Modern Slavery Actâ€).  It covers ÁñÁ«ÊÓÆµâ€™ activities for the prior fiscal year (FY2022) and applies to all ÁñÁ«ÊÓÆµ employees, officers, directors, agents, consultants, and any other persons acting on behalf of any entity owned or controlled by ÁñÁ«ÊÓÆµ (“ÁñÁ«ÊÓÆµ Personnelâ€) anywhere in the world.  Where applicable, this Statement also addresses ÁñÁ«ÊÓÆµâ€™ ongoing efforts to comply with the U.S. Uyghur Forced Labor Prevention Act (“UFPLAâ€), the California Transparency in Supply Chains Act (“CTSCAâ€), and anti-slavery standards published by the International Labor Organization (“ILOâ€) (collectively “Anti-Slavery Lawsâ€).

Organization & Structure

Headquartered in Amsterdam, ÁñÁ«ÊÓÆµ is a Hospitality Management Platform (“Hospitality Company") company that develops, deploys, and supports hospitality property management software solutions.  ÁñÁ«ÊÓÆµ employs approximately 1,300 individuals from office and remote working locations in Australia, Belgium, the Czech Republic, France, the Netherlands, Spain, the United Kingdom, the United States and others.

Policies & Procedures

ÁñÁ«ÊÓÆµ is committed to promoting human rights and fair treatment for all persons.  With these values in mind, ÁñÁ«ÊÓÆµ strictly prohibits all forms of Slave Labor identified under the Modern Slavery Act and other applicable anti-slavery laws.  Notable examples include, without limitation, bonded labor, child labor, forced labor, prison labor, and other forms of indentured servitude.  ÁñÁ«ÊÓÆµ also prohibits any form of Human Trafficking, including the transportation, harboring, recruitment, transfer, or receipt of persons by means of threat, fraud, force, exploitation, coercion, or abduction.  These prohibitions extend to all ÁñÁ«ÊÓÆµ Personnel regardless of their location, nationality, or role within the enterprise.

In addition to overseeing its own activities, ÁñÁ«ÊÓÆµ also has zero tolerance for any use of Slavery or Human Trafficking by its agents, consultants, contractors, and other third-party suppliers and vendors (“Third Party Suppliersâ€).  We expect that all Third Party Suppliers will comply with applicable wage and labor laws in the countries where they operate, and will meet internationally-recognized ILO standards in those instances where local and national laws may prove deficient.  Consistent with this zero tolerance policy, the company encourages any ÁñÁ«ÊÓÆµ Personnel who reasonably suspect potential non-compliance by Third Party Suppliers to notify their managers or ÁñÁ«ÊÓÆµâ€™ Legal Department consistent with the company’s Whistle-Blower Policy.

Supply Chain Integrity

Although the use of Slavery and Human Trafficking is comparatively rare in the Hospitality Management Platform sector, ÁñÁ«ÊÓÆµ reserves the right to terminate Third Party Suppliers that engage in any form of Slavery or Human Trafficking.  ÁñÁ«ÊÓÆµ also plans to seek the right to audit compliance with these standards as part of our Third Party Supplier onboarding process.  In those instances where Third Party Suppliers may pose potential Slavery or Human Trafficking risks, ÁñÁ«ÊÓÆµ may also conduct its own independent investigations into their activities and request certifications attesting to their compliance with the Modern Slavery Act and other applicable Anti-Slavery Laws. 

Assessing & Managing Risk

As a Hospitality Management Platform company, ÁñÁ«ÊÓÆµ does not rely on foreign products, materials, or components.  ÁñÁ«ÊÓÆµ currently has no international supply chains and does not currently deal in any of the sectors commonly associated with forced labor, human trafficking, and other forms of indentured servitude.  ÁñÁ«ÊÓÆµ also has limited exposure to the countries appearing in the 2023 Global Slavery Index published by Walk Free, a leading non-governmental organization specializing in combatting forced labor and human trafficking.1  To the extent that ÁñÁ«ÊÓÆµ hires employees or engages Third Party Personnel from the high-risk jurisdictions appearing in the Global Slavery Index, it typically does so pursuant to robust labor and employment laws administered by governments in North America, Western Europe, and other jurisdictions where Slavery and Human Trafficking are comparatively rare.

It is also important to note that the Hospitality Management Platform industry involves a highly skilled, highly mobile workforce where employees typically benefit from high demand for their services, and, by extension, higher wages.  This is particularly true for ÁñÁ«ÊÓÆµ, which provides specialized Hospitality Management Platform systems, software, and services to hotels and other similar establishments.  Although some these third-party customers could theoretically experience elevated exposure to domestic Anti-Slavery Laws given the nature of their business, there is currently no reason to suspect that these third-party risks would implicate, much less adversely affect, ÁñÁ«ÊÓÆµâ€™ own operations. Working from this basis, ÁñÁ«ÊÓÆµ currently has no information indicating that it or its Third Party Suppliers engage in any activities contrary to the Modern Slavery Act or other Anti-Slavery Laws.

Employee Training & Reporting

ÁñÁ«ÊÓÆµ is committed to conducting business with honesty and integrity.  To that end, any ÁñÁ«ÊÓÆµ Personnel who observe any potential or actual violations of the Modern Slavery Act or other applicable Anti-Slavery Laws are encouraged to contact their Managers or the company’s Legal Department in a manner consistent with ÁñÁ«ÊÓÆµâ€™ Whistleblower Policy.  The company does not permit any form of retaliation against ÁñÁ«ÊÓÆµ Personnel who report suspect violations of any Anti-Slavery Laws or related company policies in good faith.  

Matthijs Welle 
Chief Executive Officer