Modern Slavery and Human Trafficking Policy

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced labor, compulsory labor, and human trafficking. PLANERGY has a zero-tolerance approach to modern slavery and we are 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 our supply chains. PLANERGY is also committed to ensuring there is transparency in our own business and in our approach to addressing modern slavery throughout our supply chains. We expect the same high standards from all of our contractors, suppliers and other business partners. 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, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

Who Must Comply with This Policy?

This policy applies to all persons working for PLANERGY or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. This policy does not form part of any employee’s contract of employment and PLANERGY may amend it at any time. It is reviewed regularly.

Our Guiding Principles

PLANERGY has made employee well-being a priority and as part of our focus on employees, we are committed to taking steps to address modern slavery. Our Guiding Principles influence everything we do. Modeling these behaviors and attitudes in a holistic manner helps our employees and business partners navigate even the most complex situations. We believe in partnering only with others who share our values and who understand the importance of always conducting business ethically. This policy governs the activities of PLANERGY with regard to addressing forced labor, human trafficking and slavery and servitude (collectively, “modern slavery”) in our business and supply chains. This statement is published pursuant to the Modern Slavery Act 2015 (UK) and the Modern Slavery Act 2018 (Cth) (the Australian Modern Slavery Act). We are committed to working with our global supply chain partners to create conditions so that no employee pays for their job; employees retain control of their travel documents and have full freedom of movement; and all employees are informed of the terms of their employment.

Our Business and Supply Chains

PLANERGY is a global leader in Spend Management, Procurement and AP Automation software. We expect all of our suppliers to operate in a responsible, ethical, open and transparent way and in compliance with all applicable laws and regulations. Based on the nature of our business, workforce, and the services we provide, we consider our business and direct supply chain to be lower risk for modern slavery. Nevertheless, PLANERGY recognizes that we have a role to play in the global effort to eliminate modern slavery and human trafficking, regardless of the level of pervasiveness across our industry. PLANERGY relies on the use of suppliers to support high quality, effective and efficient delivery of our services to customers. Our suppliers are predominantly public, global, registered businesses and professional services organizations, in particular companies that develop and license software or provide cloud-based applications or hosting solutions. Other areas of indirect spend primarily include marketing and other consulting services from third-party providers; travel, hospitality and food catering services; back-office software services; computers and IT equipment; and general office supplies. The vast majority of our major suppliers are headquartered in low-risk countries, are global leaders in their industries, and operate and publish very comprehensive Modern Slavery best practices and statements.

Our Policies, Training and Principles

Code of Business Conduct

All PLANERGY employees must comply with our Code of Business Conduct, which explicitly forbids the use of forced or involuntary labor in any of our locations or in any of our suppliers. Violation of our Code of Business Conduct by an employee can result in disciplinary action, including termination of employment.

Internal Training

We understand that training is crucial to raising awareness of issues around modern slavery including how to spot signs of trafficking and where to report concerns. As part of our onboarding and ongoing training we include Modern Slavery as part of our Ethics and Sustainability training.

Global Compliance Principles

Our contracted suppliers are expected to comply with PLANERGY’s terms of engagement, and our Global Compliance Principles are informed by the International Labour Organization, the Fair Labor Association, and other international standards on human rights. Suppliers are prohibited from engaging subcontractors to produce PLANERGY work output. Updated July 2020