Cuckoo International (MAL) Sdn Bhd and its subsidiaries (“the Group”, “we”, “us” or “our”) are committed to limiting the risk of modern slavery occurring within its own businesses, infiltrating its supply chain or through any other business relationship.
This Anti-Slavery Policy (“Policy”) applies to all persons working for or on behalf of the Group, in any capacity, including employees, directors, officers, and business associates. Business associates refer to any party who has or will have business dealings with the Group, including without limitations vendors, suppliers, agents, representatives, consultants, intermediaries, advisers, contractors, sub-contractors, joint venture partners, outsourcing providers, and all parties who act on behalf of the Group.
The Group expects all who have, or seek to have, a business relationship within the Group to familiarise themselves with this policy and to act in a way that is consistent with its values.
- Modern Slavery
Modern slavery can take many forms, including but not limited to those listed below:
- Slavery: where ownership is exercised over an individual. )
- Servitude: involving the obligation to provide service imposed by coercion.
- Forced and compulsory labour: all work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty.
- Human trafficking: involving, arranging, or facilitating the travel of another with a view to exploiting them.
- Child labour: whilst not always illegal in the jurisdiction in which it takes place, child labour involves the employment of children that is exploitative or is likely to be hazardous to or interfere with a child’s education, health (including mental health), physical wellbeing or social development.
All forms of modern slavery have in common, the deprivation of a person’s liberty by another in order to exploit them for commercial or personal gain and amount to a violation of an individual’s fundamental human rights.
The Group has a zero-tolerance approach to modern slavery and is 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 business or any of our supply chains.
To underpin the commitments laid out in this Policy, the Group aims to implement the following measures:
- Ensuring employees are paid within the boundaries of the company’s pay policies, and which in all cases exceed the prevailing minimum wage levels applicable under the legislation.
- Contractual documentation will incorporate specific prohibitions against slavery or servitude, the use of forced, compulsory or trafficked labour, and the use of child labour in line with this Policy.
- The Group’s contracted suppliers will be encouraged to hold their own suppliers to the same standards. The Group will reserve the right to terminate any contractual agreement if there is a breach of this Policy.
- Have in place an open and transparent grievance process for all individuals
- Breaches of this Policy/Responsibilities/ Policy Compliance
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or in partnership with us. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. The consequences of failing to effectively manage modern slavery risk can be significant from a regulatory and reputational perspective as well as the obvious human impact.
You must notify your line manager or report via the confidential Whistleblowing Channel as soon as possible if:
- You believe or suspect that a breach of this policy has occurred or may occur in the future;
- You have any concern or suspicion that may be an issue in respect of modern slavery in any part of our business, or within the supply chains of any third-party suppliers; and/or
- You are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within our own business or any part of our supply chains constitutes any of the various forms of modern slavery.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment by reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our business or any of our supply chains.
- Breaches of this Policy
The breach of this policy by an employee, contractor, supplier or director of the Company may lead to disciplinary action being taken. Serious breaches by employees may be regarded as gross misconduct and can lead to immediate dismissal. All employees will be expected to cooperate to the fullest extent possible in any investigation into suspected breaches of this policy or any related processes or procedures.
- Status of this Policy
This Policy will be reviewed on a regular basis and updated to reflect legal and operational requirements.
15th November 2022