Modern Slavery Policy

Purpose

This Modern Slavery Policy sets out InTalent Asia’s general approach to preventing and discouraging modern slavery, forced labour, human trafficking, child labour, and other forms of exploitation within its business operations and, where relevant, its supply chain and business relationships.

As a company operating in recruitment, executive search, workforce solutions, and HR services, InTalent Asia recognises the importance of responsible employment practices, ethical recruitment, and respect for human dignity.

Scope

This policy applies generally to InTalent Asia’s operations and to persons acting on behalf of the company, including directors, employees, consultants, contractors, and, where relevant, suppliers, service providers, and other business partners.

Application of this policy may vary depending on the nature of the relationship, geographic location, applicable law, contractual arrangements, and the level of control or influence available to the company.

Policy Statement

InTalent Asia does not support modern slavery, forced labour, bonded labour, compulsory labour, human trafficking, child labour, or any form of unlawful exploitation. The company seeks to conduct its business in a manner that promotes lawful, ethical, and responsible workforce practices and may take reasonable and proportionate steps to identify and address relevant risks within its own operations and, where appropriate, in connection with third party relationships.

InTalent Asia also recognises that risk levels may differ across sectors, service providers, locations, and business arrangements, and that risk management should be proportionate to the company’s role, visibility, and operational context.

Key Principles

InTalent Asia may seek to:

  • promote ethical recruitment and employment related practices
  • avoid knowingly engaging in or supporting business activity linked to modern slavery or exploitation
  • assess relevant third party or supplier risks where appropriate and proportionate
  • encourage responsible conduct by persons acting on behalf of the company
  • support the raising of genuine concerns relating to exploitation or suspected unlawful labour practices
  • review and strengthen relevant internal controls, contractual expectations, or supplier standards over time where considered appropriate

Recruitment and Business Practices

InTalent Asia may seek, where relevant and practical, to:

  • support lawful and ethical hiring and workforce practices
  • avoid charging candidates prohibited or unlawful recruitment related fees where such practices would be inconsistent with applicable law or company standards
  • promote professional conduct in its dealings with candidates, employees, clients, and business partners
  • encourage responsible conduct by persons acting on behalf of the company
  • communicate relevant expectations to suppliers and service providers where appropriate
  • review relationships or arrangements that may present material legal, ethical, or reputational concerns

Roles and Responsibilities

01. Leadership

Leadership may oversee the company’s general approach to modern slavery risk awareness and responsible workforce practices.

02. Managers

Managers may support awareness, escalate material concerns, and apply relevant company controls or expectations within their areas of responsibility.

03. Employees and Representatives

Employees and persons acting on behalf of InTalent Asia are generally expected to avoid involvement in exploitative practices, remain alert to serious concerns, and raise genuine issues through appropriate channels.

04. Suppliers and Third Parties

Where relevant, InTalent Asia may communicate expectations to suppliers and service providers and may take such matters into account in onboarding, review, renewal, or other commercial decisions.

Reporting Concerns

Any genuine concern regarding suspected forced labour, trafficking, exploitation, unlawful child labour, coercion, or related conduct may be raised through appropriate internal channels or designated company contacts.

InTalent Asia may review reported matters and determine any action it considers appropriate, taking into account the seriousness of the issue, available evidence, contractual position, legal considerations, confidentiality, and the company’s practical ability to influence the relevant arrangement.

Monitoring and Review

InTalent Asia may review this policy and related internal practices from time to time in light of legal developments, operational needs, client expectations, supplier risk factors, and broader ESG priorities.

Policy Status

This policy is intended as a general statement of InTalent Asia’s approach to modern slavery related risks and responsible business practices. It does not create contractual or legally enforceable rights or obligations for any third party, except to the extent required by applicable law.

InTalent Asia may amend, replace, suspend, or withdraw this policy at any time, subject to applicable legal and regulatory requirements.

Related Standards and Policies

This policy should be read together with the ESG Policy, Equal Employer Policy, Supplier Code of Conduct, Business Ethics and Code of Conduct, and other related company policies adopted by InTalent Asia from time to time.

Where relevant, aspects of this policy may also be supported through the company’s broader governance, quality, privacy, and information management approaches aligned to ISO 9001, ISO 27001, and ISO 27701.

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