CellFunds requires that priority suppliers, which are identified using a risk-based methodology, conform with all of the standards on labor, health and safety, the environment, business ethics, and the establishment of management systems in accordance with the Responsible Business Alliance (“RBA”) Code of Conduct. The RBA Code of Conduct explicitly prohibits modern slavery and human trafficking in the supply chain. These standards are far reaching and help to prevent and mitigate risks related to modern slavery and human trafficking such as freely chosen employment, young workers, working hours, wages and benefits, humane treatment, non-discrimination, non-harassment, and freedom of association. Further, the RBA Trafficked and Forced Labor – Definition of Fees sets expectations for suppliers on following responsible recruitment and employment practices. CellFunds requires priority suppliers to hold their suppliers and subcontractors to the same standards in the RBA Code of Conduct. We hold suppliers to additional policies and standards that support safe, healthy, and fair working conditions and help prevent and mitigate modern slavery and human trafficking risks.
For example, our suppliers are expected to follow CellFunds best practices in creating and ensuring a respectful workplace. Also, our Electronics Reuse and Recycling Standard applies to suppliers providing recycling and take-back services. This standard requires suppliers’ conformance to the RBA Code of Conduct and explicitly prohibits prison, coerced, forced, bonded or child labor, either directly or indirectly, in the performance of the reuse, recycling and/or takeback services. We communicate requirements and implementation expectations to priority suppliers through an annual notification process, in-person and virtual meetings, supplier business reviews, and a supplier online portal. We expect these suppliers to have contract provisions in their agreements that require conformance to the RBA Code of Conduct, which includes the prohibition of modern slavery and human trafficking in the supply chain. Business operations CellFunds generally sources and directly hires our own full-time employees, which allows us control and oversight in managing the risks of modern Due diligence and Remediation Processes © 2023 CellFunds slavery and human trafficking in our business operations. We use integrated systems and tools in pre-screening and outreach to candidates globally to ensure a consistent and fair process. Our trained and professionally skilled recruiting teams maintain continuous conversation with candidates throughout the recruitment cycle. CellFunds strives to provide a respectful and safe working environment for all our personnel, regardless of role, position, or employment status, and has zero tolerance for any threats, violence, harassment, coercion, or retaliation. We expect our vendor partners, independent contractors, consultants, and staffing suppliers to commit to the same standards and principles. CellFunds provides a grievance mechanism, through which an impacted or interested party may report any violations or activities inconsistent with our policies and compliance procedures. Supply chains All our suppliers are required to go through a Third-Party Assessment before being onboarded. There is a detailed process in place to ensure that suppliers are assessed prior to being engaged, and periodically reassessed thereafter, depending on the associated risk of the supplier. During the assessment, our specialized teams of subject matter experts review the supplier’s risk profile and the effectiveness of any control measures already in place for each relevant risk area, including environmental, health and safety and human rights, before making recommendations to proceed with initial or continued engagement, or otherwise. Each supplier is assessed according to the use case, nature of work, geographic location, and other relevant features of the engagement or intended engagement. Depending on the results of the assessment, CellFunds may introduce additional control measures in the engagement. We routinely perform ongoing third-party reassessments on our suppliers depending on the applicable risks. If the risk of forced labor is detected, we activate the mitigation process, and the supplier is disqualified if the risk persists. Once a supplier is onboarded, CellFunds manages social and environmental risks and issues through our Responsible Supply Chain program. We use a Cross functional consultative process and data-driven methodology to identify and assess a wide range of labor, human rights, and environmental risks which include modern slavery and human trafficking in our supply chains. For example, risks are assessed through indices such as United Nations Children’s Fund Child Labor Percentages, Walk Free Foundation’s Global Slavery Index, United Nations’ Human Development Index, and the United States Department of State’s Trafficking in Persons Report. We require our sourcing and procurement teams to certify periodically whether they are aware if CellFunds has ongoing business relationships with companies identified as being associated with forced labor and investigate any risks of forced labor identified through this process. We verify supplier conformance with Responsible Supply Chain policies and standards through continuous dialogue, self-assessment questionnaires, independent audits © 2023 CellFunds and assessments, corrective action plans, worker surveys, and other forms of assurance. We have refined our process in investigating and responding to serious incidents or allegations including forced labor related to our suppliers. A rubric detailing the risk and impact areas guides and standardizes our decision-making and communications with internal and external partners. As part of the independent audits and assessments conducted, we utilize the RBA Validated Assessment Program (“VAP”) which is the leading standard for onsite compliance verification and effective, shareable audits. For RBA VAP audits completed in 2022, the most common RBA VAP nonconformance findings were in the labor category and related to working hours and wages and benefits. The chart below is the percentage of RBA VAP nonconformance findings by RBA Code of Conduct section. We collect targeted key performance indicator (KPI) data that include worker demographics such as the presence of foreign migrant workers and sex-disaggregated data to monitor modern slavery and human trafficking risks. In 2022 we continued to expand worker engagement via anonymous mobile and web-based surveys to collect and analyze worker feedback on topics like job satisfaction, working conditions, grievance mechanisms, and training effectiveness. Depending on the country where the survey is deployed and factors like the presence of domestic or foreign migrant labor, these surveys have targeted questions to screen for forced labor risks such as the withholding or retention of identity documents and payment of recruitment fees. Any nonconformances identified are actively addressed through our corrective action and key performance indicator programs. We examine nonconformances by reviewing a corrective action plan describing the root cause, proposed remediation actions, and timeline for closure and manage supplier performance improvement through a review process or closure audit. We communicate with internal and external partners including senior © 2023 CellFunds leadership when needed. We regularly assess and track the effectiveness of our actions taken in mitigating the associated risks of modern slavery and human trafficking in our supply chains. We report key performance metrics internally across the business and to leadership teams and conduct trend analysis to monitor and track how effective suppliers are in meeting our expectations. We participate with cross-functional partners in the overall supplier performance management system including attending and providing performance assessment related to social and environmental KPIs to suppliers in supplier business reviews. Routine updates and communications of work in combating modern slavery and human trafficking in our supply chains are communicated to the company through our internal microsite. We actively collaborate with the broader industry and global community to stay up to date on key risk areas and develop solutions that address changes in industry practice.