Last Updated: October 28, 2024

1. Purpose and Scope

Eloquent AI is committed to conducting its business ethically, responsibly, and in compliance with all applicable laws relating to human rights, labour, and fair working conditions. This policy outlines Eloquent AI’s commitment to preventing modern slavery, human trafficking, and forced or compulsory labour within its operations and global supply chain.

It applies to:

  • Eloquent AI Inc. (United States)
  • Eloquent AI Ltd. (United Kingdom) 

and extends to all employees, contractors, suppliers, and business partners engaged by the company.

2. Definitions

For the purposes of this policy:

  • Modern slavery includes slavery, servitude, forced or compulsory labour, and human trafficking.

  • Human trafficking is the recruitment, transportation, or harbouring of people for the purpose of exploitation.

  • Supply chain refers to all suppliers, subcontractors, service providers, and other entities directly or indirectly supporting Eloquent AI’s operations.

These definitions are aligned with the UK Modern Slavery Act 2015 and relevant US federal and state human-trafficking legislation, including the Trafficking Victims Protection Act (TVPA).

3. Policy Statement

Eloquent AI has zero tolerance for any form of modern slavery or human trafficking. We are committed to acting ethically, with integrity, and to implementing effective systems and controls to ensure that modern slavery does not occur in any part of our business or supply chain.

Our commitments include:

  • Prohibiting the use of forced, bonded, or involuntary labour in all operations.
  • Ensuring that all employment is voluntary and that workers are free to leave with reasonable notice.
  • Preventing the use of child labour in contravention of international standards.
  • Expecting all suppliers and partners to uphold equivalent standards.
  • Promoting transparency and accountability through our governance and due diligence practices.

4. Responsibilities

Leadership and Management
Eloquent AI’s leadership team is responsible for maintaining and reviewing this policy, ensuring adequate risk management and supplier oversight mechanisms are in place.

Employees
All employees are required to comply with this policy and to report any suspected instances of modern slavery or exploitation in Eloquent AI’s operations or supply chain to the designated compliance contact or their line manager. Failure to report known or suspected breaches may be treated as a disciplinary matter.

Suppliers and Partners
Eloquent AI expects all suppliers and service providers to uphold the same high standards. Suppliers must:

  • Comply with all applicable anti-slavery and human-trafficking laws.
  • Maintain transparent recruitment and employment practices.
  • Cooperate with reasonable due diligence or audit requests from Eloquent AI.

5. Risk Assessment and Due Diligence

Eloquent AI acknowledges that risks of modern slavery can arise at various points in the supply chain, particularly in sectors such as technology hardware manufacturing, third-party labour, and outsourced services.

We mitigate these risks through:

  • Conducting supplier assessments focusing on data security, privacy, and ethical sourcing.
  • Requiring suppliers to confirm compliance with applicable labour and human-rights laws.
  • Engaging only with vendors that demonstrate ethical business practices and transparent policies.
  • Reviewing supplier performance and compliance periodically as part of our broader SOC 2 and ISO 27001 controls.

6. Reporting Concerns

Any employee, contractor, or partner who suspects a breach of this policy should report it promptly to the designated compliance contact through internal channels. Reports will be handled confidentially, and retaliation against any individual who raises a concern in good faith will not be tolerated. 

All suspected breaches will be investigated, and appropriate action, including reporting to law-enforcement authorities, will be taken where necessary.

7. Training and Awareness

Eloquent AI will raise awareness of modern slavery and human-rights risks during employee onboarding and through periodic compliance updates for relevant teams. This ensures that staff understand the company’s values, obligations, and the signs of potential exploitation within business relationships.

8. Continuous Improvement

We are committed to continuous improvement in identifying, mitigating, and preventing modern-slavery risks. This includes reviewing this policy annually and integrating modern-slavery considerations into broader risk-management and supplier-assessment processes.

9. Review and Approval

This policy is reviewed annually by the Compliance and Legal teams and approved by the Board of Directors. It will be updated as required to reflect legislative changes, operational developments, or emerging risks.

Approved by: Tugce Bulut, Chief Executive Officer, Dr Aldo Lipani, Chief AI & Innovation Officer
 

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