Modern Slavery Statement

Modern Slavery & Human Trafficking Policy

BACKGROUND
On March 26, 2015, The Modern Slavery Act 2015 was passed into law in the United Kingdom. This law requires all business entities that carry on a business, or part of a business, in any part of the United Kingdom to prepare and publish a slavery and human trafficking statement for each financial year of the organisation. The law also creates the obligation to report on steps taken during the financial year to ensure that slavery and human trafficking is not taking place in any part of its supply chain or in any part of its own business. Johnson Controls has business entities operating in the UK, therefore Johnson Controls abides by this law.

SCOPE
This policy applies to Crafti’s business operations. Employees whose responsibilities relate to the sourcing of parts, components, and materials are informed and are expected to assist our compliance with these requirements, associated legislation, and regulations. This policy is reviewed annually and changes are incorporated accordingly.

OUR COMMITMENT
We respect the environment, the communities in which we operate, and our employees’ human rights, and we oppose corruption. Therefore, we are committed to conducting our worldwide business operations in a manner that complies with applicable laws and regulations. We are also committed to taking steps to ensure that slavery and human trafficking is not taking place in any part of our supply chain or in any part of our business. This commitment is in alignment with our Human Rights and Sustainability Policy and our Ethics Policy which define how we abide by these principles and related global standards.

OUR EXPECTATIONS
Crafti’s expect our suppliers not to be involved in forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery or trafficking of persons of any age at any tier of the supply chain. This includes transporting, harbouring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. Suppliers, as employers or agents, may not hold or destroy employees’ identification or immigration documents, such as government-issued identification, passports or work permits, unless the holding of work permits is required by law. Employers may not restrict workers’ freedom of movement in the facility or entering or exiting company-provided facilities. All work must be voluntary and workers shall be free to terminate their employment and leave work at any time. Employers and agents may not use misleading or fraudulent practices during the recruitment of employees. As part of the hiring process, workers must be provided with a written employment agreement in their native language that contains a description of terms and conditions of employment and the hazardous nature of the work, prior to the worker departing from his or her country of origin. Workers must not be required to pay employers’ or agents’ recruitment fees or other related fees for their employment. If any such fees are found to have been paid by workers, such fees must be repaid to the worker. We expect our suppliers to have a compliance plan in place to ensure that human trafficking and forced labor are not used and that risks of worker exploitation are mitigated. We will continue to promote and encourage our suppliers to take steps to ensure that slavery and human trafficking is not taking place in any part of our supply chain or in any part of their businesses. We expect our suppliers to conduct due diligence on their respective supply chains and to assist us with our compliance with these rules. To the extent that a supplier refuses to cooperate with our compliance efforts, we may reconsider our supply arrangement and implement remedies available to us.

Child Labour Policy

This Child Labour Policy recognises Crafti’s Ltd commitment to ensuring all employees are of the local minimum employment age.

Crafti’s Ltd does not accept child labour. Child labour is defined as work undertaken by a child which; the child is legally prohibited from undertaking or is likely to be harmful to the Child’s health or physical, mental, spiritual, moral, or social development; or interferes with a Child’s education. All actions concerning the child shall take full account of his or her best interests. The right of the child to be protected from economic exploitation, from preforming any work that is likely to be hazardous or interferes with the child’s education, or is harmful to a child’s health or physical, mental, spiritual, moral or social development.

Implementation

Crafti’s Ltd will take the appropriate measures to ensure no child labour occurs within the organisation including all subcontractors and homeworkers contracted. This includes but is not limited to; Recruitment policies verifying age documentation of employees.

Register of labour force

Crafti’s Ltd will collect and maintain documentation from every worker verifying the age of each employee. This can be copies of original documents such as Identification cards, or birth certificates, or passports, visas etc. Crafti’s Ltd will not collect, or hold on to, original documentation for any reason.Where such documentation is not available, all efforts will be made to assess and verify age of employees as per local practice or law.

Forced Labour Policy

1. ABOUT THIS POLICY
This policy shall give a clear guidance to all our supply chain members on the position we take towards forced labour. At the same time, it shall enable all involved parties in the production of our goods to avoid and remedy forced labour. Whilst we are aware of the challenges related to the detection and ending of forced labour in our supply chain, we ask our direct business partners to support this cause by cascading this policy down their own supply chain to any business involved in the production of our goods.

2. OUR POSITION
Crafti’s Ltd are committed to working with our suppliers to improve working conditions in our supply chain and to strive for the detection and ending of forced labour together with our partners. But we have a zero tolerance concerning the inaction and cover up of human rights violations like forced labour. Therefore we reserve the right to end our business relationship with any company who is connected to any form of forced labour and is not acting upon it or even covering it up.

3. DEFINITIONS
“Forced or compulsory labour is all work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself or herself voluntarily.”

The following Indicators of forced labour represent the most common signs for the possible existence of forced labour:

• Abuse of vulnerability
• Deception
• Restriction of movement
• Isolation
• Physical and sexual violence
• Intimidation and threats
• Retention of identity documents
• Withholding of wages
• Debt bondage
• Abusive work and living conditions
• Excessive overtime

The presence of only one indicator can already point to the existence of forced labour. Multiple indicators can also be observed at the same time.

4. LABOUR RIGHTS AND FORCED LABOUR
Forced Labour must not always be intentional, but can also be derived and triggered by not respecting and not complying with labour rights.

• When for example the one time non-payment of wages becomes a regular habit: “The fact of irregular or delayed payment of wages does not automatically imply a forced labour situation. But when wages are systematically and deliberately withheld as a means to compel the worker to remain, and deny him or her of the opportunity to change employer, this points to forced labour.” By always paying wages regularly and on time as well as the agreed amount, will minimise the risk of this specific labour rights violation, which can lead to forced labour.
• “Victims of forced labour are often recruited with promises of decent, well-paid jobs. But once they begin working, the promised conditions of work do not materialise, and workers find themselves trapped in abusive conditions without the ability to escape. In these cases, workers have not given free and informed consent.” A legal and written contract which has been understood by all signing parties and stating clearly the conditions of work, can help to avoid deceptions on both sides and avoid forced labour.

5. OUR EXPECTATIONS TOWARDS OUR DIRECT BUSINESS PARTNERS AND OUR DEEPER SUPPLY CHAIN
To be able to identify behaviour which is not in compliance with this policy, recommend to our direct business partners to map their supply chain and to identify possible risk areas for the existence of forced labour.

5.1. AVOID FORCED LABOUR

5.1.1. All work must be conducted on a voluntary basis, and not under threat of any penalty or sanctions. 
5.1.2. The use of forced or compulsory or unpaid labour in all its forms, including prison labour and unpaid overtime work, is prohibited.
5.1.3. Workers shall not be required to make deposits / financial guarantees and the identity documents of any worker (such as passports, identity cards, etc.) shall not be confiscated. No delayed payment of wages shall occur.
5.1.4. The right of workers to terminate their employment after legal notice shall be respected.
5.1.5. The right of workers to leave the workplace and factory after their shift shall be respected.
5.1.6. A hiring policy shall be available, including:

A clear statement against forced labour. 
A process, designed to avoid any form of compulsory or forced labour.
A commitment to remedy the consequences caused by failing this policy (see below).

5.2. REMEDY FOR WORKERS AFFECTED BY FORCED LABOUR

5.2.1. If any form of forced or compulsory labour is detected in our supply chain, we and the appropriate authorities shall be informed immediately.
5.2.2. The company practicing forced or compulsory labour shall remedy the damages caused, may they be related to financial, health or other matters.
5.2.3. We will follow up the remedy process in accordance with involved authorities and conduct a root cause analysis with the company, designed to avoid further cases of forced labour.