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Policy Number: AUS-07P-01001

Sponsor: Office of the Executive Vice President and Treasurer

Effective Date: September 3, 2021


A. PURPOSE


Modern slavery encompasses slavery, forced and compulsory labor, and human trafficking, whereby individuals are deprived of their freedom and are exploited for commercial or personal gain. The University also considers other related malpractice, including child labor, unsafe working conditions, or excessive working hours, within this definition for this policy.


The American University of Science ("AUS", "University", "university") is committed to ensuring no modern slavery in our supply chains or any part of our business. The processes below reflect the University’s commitment to acting ethically and with integrity across the institution.


B. APPLICABILITY


This policy applies to all employees, workers, consultants, and other persons doing business with the University, including all its wholly owned or controlled subsidiaries or majority joint ventures, contractors, and direct suppliers.


C. STATEMENT


1. Principles


1.1. The prevention, detection, and reporting of modern slavery (and other related malpractice listed in the ‘scope’ section above) in any part of its business or supply chains is the responsibility of all those working for the University or under its control.


1.2. Appropriate human capital and due diligence processes must be carried out concerning modern slavery. This includes consideration of human rights practices in a sector or country, the type of sector in which a service provider operates, the countries from which services are provided, the nature of relationships with suppliers, and the complexity of supply chain(s).


1.3. Although the University as a higher education institution considers the risk of modern slavery to be comparatively low in its direct activities and supply chain, it takes its responsibilities to combat modern slavery seriously as demonstrated by its promotion and adoption of the following policy measures.


2. Key Controls


2.1. Procurement

The University procures goods and services from suppliers across the world. It has supporting systems in place to identify and assess potential risk areas and to mitigate the risk of slavery and human trafficking occurring in our supply chains.


2.2. Training


All members of the purchasing-related unit receive training on supplier review templates and guidance. The University provides its managers with training and guidance on the recruitment process.


2.3. Communications and Awareness-raising


The University highlights modern slavery issues within its ongoing communications with working units and current trade suppliers to maintain and increase awareness of the issue.


2.4. Raising Concerns


The University encourages anyone to raise any concerns about modern slavery. This can be done directly to line management, to the Compliance@TheAUS.us email address, which aims to provide a transparent and confidential process for staff to disclose concerns about possible malpractices or improprieties. The University places the most significant importance on the integrity of its operations and will support anyone who acts in good faith.


2.5. Recruitment, Reward, Equalities, and Wellbeing


The University is committed to ensuring that people are paid appropriately for the work that they carry out. Its recruitment, reward, equality, and well-being policies support its efforts to combat modern slavery and human trafficking.


2.6. Future Commitments


The University will continue to develop its commitment to combat modern slavery and will outline such activities within its annual anti-slavery and anti-trafficking statement. This includes developing and improving its key performance indicators to help it better assess its effectiveness at identifying and managing risks related to modern slavery in its operations and supply chain.


2.7. Action in the Event of a Breach


Any breaches of this policy may result in the University taking disciplinary action against individual(s) and/or terminating its relationship with any organization or supplier.


2.8. Anti-slavery and Anti-trafficking Statement


The University must also prepare an anti-slavery and anti-trafficking statement for each financial year, setting out what steps it has taken to ensure that modern slavery is not taking place in its business or supply chains.

ANTI-SLAVERY AND ANTI-TRAFFICKING POLICY

OFFICE OF THE EXECUTIVE VP

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