Introduction
Modern slavery is a crime and a violation of fundamental human rights. It takes many forms, including slavery, servitude, forced and compulsory labor, bonded labor, child labor, and human trafficking. All of these deprive a person of their liberty and are exploited for personal or commercial gain.
Turbo.net has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting with integrity and transparency in all our business dealings and relationships, and to putting effective systems and controls in place to safeguard against any form of modern slavery occurring within our business or supply chain.
Scope
This policy applies to all individuals working at all levels and grades, including senior managers, directors, officers, employees (whether permanent, fixed-term, or temporary), contractors, consultants, agents, suppliers, and any other person associated with Turbo.net, wherever they are located.
Our Commitments
Turbo.net is committed to:
- Ensuring that no form of forced, compulsory, trafficked, or child labor is used anywhere in our business or supply chain
- Paying all workers a fair and legal wage, in a timely manner, directly and in full
- Ensuring all workers are free to leave their employment with reasonable notice and are not subject to any form of penalty or debt bondage
- Ensuring workers are not required to surrender identity documents, passports, or visas as a condition of employment
- Respecting workers' rights to freedom of movement and freedom of association
- Providing safe and healthy working conditions that comply with applicable laws and regulations
- Not engaging suppliers or contractors who knowingly use or benefit from modern slavery
Supply Chain Due Diligence
Turbo.net recognises that modern slavery risks can exist across supply chains. To identify and address these risks, we will:
- Assess the risk of modern slavery in our supply chain, taking into account sector, geography, and the nature of goods and services procured
- Include anti-slavery and human trafficking requirements in supplier contracts and procurement processes
- Request that key suppliers confirm compliance with applicable modern slavery laws and this policy
- Undertake targeted due diligence on higher-risk suppliers and take appropriate action where non-compliance is identified
- Encourage suppliers to apply the same standards to their own supply chains
Risk Assessment
We evaluate modern slavery risk based on factors including:
- Country of operation and associated regulatory environment
- Industry sector and type of work performed
- Use of labor-intensive processes or low-skilled migrant workers
- Complexity and geographic spread of supply chains
Identified risks are reviewed periodically and inform the level of due diligence applied to suppliers and partners.
Training and Awareness
Turbo.net ensures that relevant employees receive training to understand the risks of modern slavery, recognise warning signs, and know how to report concerns. Training is provided as part of employee onboarding and refreshed periodically.
Reporting Concerns
All employees and those working on behalf of Turbo.net are encouraged to raise concerns about any suspicion of modern slavery or human trafficking as early as possible. Concerns may be reported to Turbo.net management through any available channel, including anonymously where possible. We are committed to protecting those who raise concerns in good faith from any form of retaliation.
If you believe someone is in immediate danger, contact the relevant emergency services. Modern slavery can also be reported to the relevant national authority in your jurisdiction.
Governance and Review
Senior management at Turbo.net holds responsibility for this policy and for ensuring the company's approach to modern slavery remains effective. This policy is reviewed annually or following any material change to our business or supply chain. We will communicate updates to all relevant stakeholders.
Exceptions
Requests for an exception to this policy must be submitted to Turbo.net management for approval.
Violations & Enforcement
Any known or suspected violations of this policy must be reported to Turbo.net management. Violations can result in disciplinary action up to and including termination of employment, or termination of a supplier or business relationship. Where violations constitute a criminal offence, Turbo.net will cooperate fully with relevant authorities.
Updated March 5, 2026