Benchmark, the United States Government, and various governmental authorities with jurisdiction over Benchmark prohibit trafficking in persons. The U.S. Government’s policy prohibiting trafficking in persons is available at 48 CFR § 52.222-50 and is summarized below under the heading: “Summary of U.S. Government Policy of Prohibiting Trafficking in Persons.” In addition, other countries may include similar laws, rules, regulations, and requirements for addressing modern slavery and human trafficking within its organization and its suppliers’ or vendors’ organizations.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Benchmark is committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
Benchmark is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Act. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labor, or anyone held in slavery or servitude, and we expect that our suppliers will hold their own suppliers to the same high standards. In addition, our suppliers also go through a due diligence procedure explained below.
Benchmark is committed to a work environment that is free from human trafficking and slavery. Benchmark will not tolerate or condone human trafficking or slavery in any part of our global organization or supply chains. Benchmark employees, subsidiaries, contractors, subcontractors, vendors, suppliers, partners and others through whom Benchmark conducts business must avoid complicity in any practice that constitutes trafficking in persons or slavery.
This policy applies to all personnel employed by or engaged to provide services to Benchmark, including, but not limited to, employees, officers, and temporary employees of Benchmark and Benchmark’s U.S. and international subsidiaries and independent contractors (for ease of reference throughout this policy, “employees”).
Every employee is responsible for reading, understanding and complying with this policy. Benchmark managers are responsible for ensuring that employees who report to them, directly or indirectly, comply with this policy and complete any certification or training required of them. If you have any questions or concerns relating to this policy, consult the Benchmark Human Resources department.
Benchmark will train all new hires on this policy and will refresh current employees at least yearly. Moreover, Benchmark will review its obligations under this policy and applicable law yearly to confirm it has complied with all statutory requirements in the United States and abroad. Where required, Benchmark will issue a Modern Slavery and Human Trafficking Statement in a timely manner.
Report any conduct that you believe to be a violation of this policy to Benchmark’s Human Resources Department directly or anonymously. Employees who fail to report actual or suspected misconduct may be deemed in violation of this policy.
The Benchmark Human Resources function, ultimately reporting to the Benchmark CEO, has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains. Training is available via the Human Resources function and will be provided on a periodic basis as appropriate to a given group or function.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to [email protected].
Any employee who violates this policy will face disciplinary action, up to and including termination of employment. We may terminate our relationship with other individuals and organizations working on our behalf if they violate this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a violation of this policy. If you believe or suspect that a conflict with this policy has occurred, or may occur in the future, or if you have concerns with working conditions or any aspect of Benchmark’s supply chains, notification to Benchmark should occur by contacting the Benchmark Human Resources team or Benchmark CEO.
As a business-to-business software company, Benchmark does not have a complex supply chain, nor does it regularly engage with companies that manufacture products. Our service providers and suppliers are mostly well-known companies that provide technology (including hardware, software, or related services) or professional service providers (including accountants, financial service providers, law firms, and other consultants).
Accordingly, while we do not perceive a high-risk company in our supply chain, as part of our procedure, all suppliers are contractually required to:
In addition, larger suppliers and those that may have an enhanced risk go through a due diligence process managed by the Human Resources department, where the supplier and its shareholders and/or officers are checked in advance, in accordance with our integrity program handled by the Human Resources department.
Benchmark will continue to monitor and engage with its supply chain in order to renew and constantly update its assessment and, if necessary, increase the due diligence and related measures taken.
Individuals at Benchmark who interact with our suppliers are also trained in different areas, including with respect to compliance with applicable laws, in order to identify and handle risks when contracting.
Benchmark will not tolerate retaliation against an employee for reporting a concern in good faith or for cooperating with a compliance investigation, even when no evidence is found to substantiate the report.
Any violation of this policy may be grounds for disciplinary action, up to and including termination. Benchmark and its subsidiaries have the exclusive right to interpret this policy regarding their respective employees.
Violation of the U.S. Government’s or any other governing body’s policy against human trafficking may also result in criminal prosecution of responsible individuals.
U.S. Government policy prohibits trafficking in persons and slavery. Government contractors and their employees, subcontractors, subcontractor employees, and agents must not engage in any practice that constitutes trafficking in persons or slavery. This includes, but is not limited to, the following activities:
