🆘Modern Slavery Policy
OVERVIEW
Given that modern slavery is one of the most severe violations of human rights, at SW | SUPER WALLET®, we have established a stringent "Modern Slavery" policy. This policy sets the standards that SW | SUPER WALLET® and its collaborators must adhere to, reflecting our firm commitment to act ethically and with integrity, and to implement and enforce effective systems and controls to ensure that modern slavery has no place within our ecosystem.
STATEMENT
SW® is committed to preventing all forms of modern slavery across its ecosystem. To achieve this goal, this policy applies to all its divisions, affiliated companies, as well as all collaborators, and works in conjunction with the company's HR policies and practices.
Furthermore, we expect our suppliers, partners, and associates to adopt similar practices to ensure that there is no place for modern slavery throughout our supply chain. We are dedicated to eradicating modern slavery and will proactively work to identify and address any potential risks in this regard across all our operations.
We trust that our suppliers, partners, and associates follow similar practices.
POLICIES
Law Compliance
SW® and all its collaborators are committed to full compliance with the law. The Constitution of the Bolivarian Republic of Venezuela (CRBV) states in Article 23 that treaties, agreements, and international conventions relating to human rights hold constitutional hierarchy and prevail within the domestic order. Furthermore, Article 54 of the Title on Civil and Political Rights of the CRBV establishes that no person can be subjected to slavery or servitude, and that human trafficking, especially that of women, children, and adolescents in all its forms, is subject to penalties prescribed by the law.
It is important to highlight that slavery, servitude, human trafficking, and forced labor are constitutionally prohibited. Neither SW® nor its collaborators can claim ignorance of the law as an excuse or acceptable defense for non-compliance with the regulations. In case of violating the law, the consequences can be severe, including the imposition of penalties provided by the law. At SW®, we take the responsibility of adhering to all applicable regulations and promoting a culture of compliance within our ecosystem.
Forced or Involuntary Labor
At SW®, our collaborators are not subjected to any form of forced, compulsory, bonded labor, or prison labor.
Human treatment
At SW®, we ensure that the workplace is an environment free from any form of harsh or inhumane treatment towards our collaborators, including harassment, mental or physical coercion, or verbal abuse. Additionally, we do not apply penalties that result in wage deductions, benefit reductions, or mandatory work for any collaborator or potential collaborator.
Equality at Work At SW®
all collaborators, regardless of their nationality or legal status, will be treated fairly and equitably.
Due Diligence Process
At SW®, we consider ourselves a 'low risk' business with regard to slavery and human trafficking. However, we conduct due diligence on new suppliers, employees, users, when we initiate a relationship with them, whether commercial or labor-related, etc. We ensure that suppliers are contractually obligated to comply with all applicable laws, including legislation on modern slavery, as well as educate our collaborators and users to share our policy.
Training
Our Modern Slavery Policy includes training on modern slavery for all new collaborators, providing appropriate training to ensure that collaborators understand the risks of modern slavery and human trafficking within our ecosystem.
Disciplinary Procedure
At SW®, we have grievance procedures in place to ensure that any collaborator, acting individually, can file a complaint without facing any form of retaliation. Any breach of this policy by a collaborator that is confirmed following an investigation shall be dealt with in conjunction with the company's relevant disciplinary policy.
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