Perforce Policy Statement Regarding Slavery and Human Trafficking
Updated as of: August 2020
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor, and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Perforce Software, Inc., and each of its subsidiary companies (“Perforce”), is committed to acting ethically and with integrity in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in Perforce’s business or in any of its supply chains.
Perforce is also committed to ensuring there is transparency in its own business and in the approach to tackling modern slavery throughout Perforce’s supply chains, consistent with its disclosure obligations under the Modern Slavery Act 2015. Perforce expects the same high standards from all of its contractors, suppliers, and other business partners. As part of Perforce’s contracting processes, Perforce includes specific prohibitions against the use of forced, compulsory, or trafficked labor, or anyone held in slavery or servitude, whether adults or children, and Perforce expects that its suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for Perforce or on Perforce’s 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.
Responsibility for the Policy
Perforce’s Board of Directors has overall responsibility for ensuring this policy complies with Perforce’s legal and ethical obligations, and that all those under Perforce’s control comply with it.
The General Counsel has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
Compliance with this Policy
Everyone working for Perforce is responsible for preventing, detecting, and reporting modern slavery if it is encountered.
If anyone becomes aware of or suspects that modern slavery is taking place, they must immediately notify our General Counsel. This applies whether or not the suspected slavery involves Perforce or one of its third party suppliers.
Perforce encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
Communication and Awareness of this Policy
Training on this policy, and on the risk Perforce’s business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for Perforce, and regular training will be provided as necessary.
Perforce’s commitment to addressing the issue of modern slavery in its business and supply chains must be communicated to all suppliers, contractors, and business partners at the outset of the business relationship with them and reinforced as appropriate thereafter.
Breaches of this Policy
Any breaches of this policy will be taken seriously and dealt with on a case by case basis.
The breach of this policy by an employee, director, or officer of Perforce may lead to disciplinary action being taken in accordance with our disciplinary procedures. Serious breaches may be regarded as gross misconduct and may lead to immediate dismissal further to Perforce’s disciplinary procedures.
Everybody to who whom this policy applies will be expected to cooperate fully with any investigation into suspected breaches of this policy or any related processes or procedures. Perforce may terminate its relationship with other individuals and organizations working on Perforce’s behalf if they breach this policy.
If any part of this policy is unclear, clarification should be sought from the General Counsel.
Status and Updates to the Policy
This policy will be reviewed by Perforce’s Board of Directors on a regular basis.
This policy does not give contractual rights to Perforce’s employees, and Perforce reserves the right to alter any of its terms at any time.