1. Introduction

NuVenture International Ltd (“NuVenture”) is committed to conducting its business with the highest level of legal, professional, and ethical standards, in compliance with Applicable Laws and based on a strong foundation of integrity. 

Slavery of any kind is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain. 

NuVenture has zero-tolerance for any form of slavery and human trafficking. 

Failing to recognize and avoid slavery can have a devastating impact on NuVenture’s reputation, business, and can create criminal and/or civil liability for NuVenture and the individuals involved. 

2. Definitions

2.1 “Activitiy(ies)” shall mean any act agreed to be refrained from and/or undertaken for and/or on behalf of NuVenture (defined hereinbelow);

2.2. “Applicable Laws” shall mean applicable statutory provisions, laws, rules, regulations, guidelines, and good governance practices, as applicable to NuVenture, including but not limited to the anti-slavery laws enacted across the various geographies where NuVenture operates, including but not limited to the UK Modern Slavery Act, 2015; 

2.3. “Business Partners” shall mean entities with which NuVenture conducts business and shall include but not be limited to: suppliers, distributors, agents, advisers, customers, brokers, sponsors, consultants, technology providers, and government and public bodies, as well as our portfolio of MGAs; 

2.4. “Code” shall mean NuVenture’s code of conduct, as set out for its Members and Business Partners; 

2.5. “Compliance Team” shall mean the team responsible for the compliance function at NuVenture;

2.6. “Conflict of Interest” means a situation where an individual or organization has competing interests or loyalties because of their duties or loyalties to more than one individual or organization; 

2.7. “Member(s)” shall mean all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, home-workers, casual workers and agency staff, volunteers, interns, agents, or any other individuals or entities associated with NuVenture, or representing NuVenture directly or indirectly;

2.8. “Policy” shall mean this Anti-Modern Day Slavery policy;

2.9. “Third Party(ies)” shall mean any individual or organization that the Members come across, directly or indirectly, while working for NuVenture; and

2.10. “NuVenture” shall have the meaning ascribed to it in section 4.

3. Policy Purpose

The purpose of this Policy is to:

3.1. establish expectations and responsibilities for the observance of and compliance with Applicable Laws; 

3.2. provide guidance on how to recognize, avoid, and report suspected acts of slavery and human trafficking; and 

3.3. prescribe the principles and controls in place to prevent, detect, and remediate slavery and human trafficking risks. 

4. Applicability

This Policy applies to any NuVenture company, subsidiary, affiliate, division, and other controlled business entity and operation, including NuVenture International Ltd as well as the directors, officers, executives, senior leaders, and employees and temporary workers thereof (collectively, “NuVenture”).  

5. Scope

This Policy shall be applicable to all Members and relevant Business Partners. This Policy must be communicated to them at the outset of their relationship with NuVenture. 

This Policy applies in all territories where NuVenture operates. Wherever local customs, standards, Laws, or other local policies also apply, the stricter rules must be complied with provided that the provisions of this Policy do not conflict with the relevant legislation. 

6. NuVenture Business

NuVenture is a UK-based managing general agent (MGA) incubation platform. It supplies comprehensive, knowledgeable services to nurture and develop various MGA businesses. 

7. NuVenture Supply Chain

NuVenture establishes a relationship of trust and integrity with all its Business Partners, which is built upon mutually beneficial factors. NuVenture endeavours to select and onboard such Business Partners who have impeccable market reputation, respect for the law, compliance with health, safety and environmental standards and respect for human rights. 

NuVenture aims to ensure that Business Partners share the same values that NuVenture holds in relation to modern day slavery and human trafficking. To manage this, NuVenture will communicate its stance in relation to Modern Slavery and Human Trafficking to all its Business Partners and seek assurance that its Business Partners hold themselves and their suppliers to the same standards. 

This, NuVenture’s anti-slavery Policy, is available to all Members and all Business Partners so that they are fully aware of NuVenture’s commitment to precenting modern slavery. NuVenture urges anyone to approach and notify them immediately if they suspect or have knowledge of any activity related to slavery or human trafficking.

8. NuVenture Policies

NuVenture has various policies in place which act as guidelines for those associated with NuVenture and emphasize its commitment to highest standard of professional conduct, ethics, and compliance with Applicable Laws. These policies are reviewed and updated from time to time, in line with NuVenture’s values and Applicable Laws and regulations. 

NuVenture’s whistleblower policy encourages all employees, customers, and Business Partners to report inter-alia any violation of a policy, Code and Applicable Laws without fear of retaliation. 

9. Supply Chain Guidelines

As a part of its responsible supply chain efforts, NuVenture:

9.1. communicates its Anti-Modern Slavery and Human Trafficking Statement to its Members, Business Partners and, where appropriate, Third Parties.

9.2. where possible, includes the key elements of this Policy in its contractual arrangements with Business Partners.

9.3. assesses the risk of slavery and human trafficking taking place within the business of its Business Partners.

9.4. has systems in place to encourage and monitor the reporting of concerns and the protection of whistleblowers.

10. Fundamentals

10.1. Business relationships with all Members, Business Partners and Third Parties must be based on compliance with the Applicable Laws.

10.2. Members must exercise due diligence while engaging with Business Partners and Third Parties. Reasonable efforts will be made to assess Business Partners and Third Parties with respect to their engagement in any acts of slavery and/or human trafficking, directly or indirectly.

10.3. Members must refuse to enter any transaction that directly or indirectly involves any form of slavery and/or human trafficking. 

10.4. Members must take all reasonable steps to ensure that all Activities undertaken are legal in nature and in compliance with the Applicable Laws and regulations.

10.5. Transparency must be maintained in all Activities. 

10.6. Members must avoid undertaking any Activity that is/may be perceived as inappropriate. 

10.7. Members must engage with Business Partners and Third Parties only for legitimate business purposes, on commercially justifiable terms. 

10.8. All Business Partners and Third Parties must be informed of NuVenture’s  commitment to this Policy and the same must form a part of their contracts. 

10.9. Members must consider the prevention, detection, and reporting of any form of violation of this Policy as their own responsibility. 

10.10. A prohibited Activity is prohibited, regardless of whether it is undertaken directly or indirectly.  

10.11. Any conflict of Interest must be disclosed promptly. 

11. Ensuring Effectiveness of the Policy

NuVenture has defined a set of key indicators and controls to combat modern slavery and human trafficking within the organization and its supply chain. These include: 

11.1. Ensuring Members complete mandatory training; 

11..2. Ensuring Business Partners are aware of NuVenture’s Policy;

11.3. Ensuring effective resolution to any complaints filed with NuVenture; 

11.4. Creating constant awareness around this Policy; 

11.5. Ensuring regular update and monitoring of the Policy; and 

11.6. Reviewing issues raised through our grievance mechanisms and initiating corrective actions. 

NuVenture shall continue to identify ways to improve its Members’ and Business Partners’ awareness of its commitment to respect human rights and efforts to prevent modern slavery and human trafficking. 

12. Training

NuVenture is committed to ensuring that all Members receive an appropriate level of training on prevention of Financial Crime, as and when required.  

All Members and relevant Business Partners are required to understand and acknowledge NuVenture’s commitment to anti-slavery and prevention of human trafficking. In addition to creating awareness around this Policy, NuVenture shall ensure to roll out the requisite training to Members.  

13. Reporting of Violations

Any violations of this Policy must be reported in accordance with NuVenture’s  whistleblower and anti-fraud policy at report@nuventure.com. 

If Members and/or Business Partners come across any red flags while working for NuVenture, they must raise concerns and report them to their manager and the Compliance Team. 

Members who refuse to take part in any prohibited Activities and/or report suspicions of a breach of this Policy in good faith will be protected from any sort of victimization or discrimination. 

14. Consequences of Non-Compliance

Violation/circumvention of Applicable Laws and regulations can result in civil or criminal liability, fines, and prohibitions on future business as well reputational damage. Companies can also incur significant costs associated with investigations of allegations into slavery and human trafficking, can be debarred from government contracting, as well as be subject to civil suits by shareholders, customers, and competitors. 

Members who violate this Policy will be subject to disciplinary action up to and including termination of employment. In addition, Members may be held personally liable for engaging in the aforesaid activities or for violating Applicable laws. NuVenture may refer suspected violations to the appropriate law enforcement agency or regulatory authority, which could lead to penalties, fines, and/or imprisonment for any Members found liable for violating the Applicable Laws. 

If NuVenture determines that a Business Partner has not complied with the provisions of this Policy, it will take an appropriate action, which may include termination of the Business Partner’s contract, initiating legal action, and/or notifying the proper authorities. 

15. Monitoring, Review & Update

All Members and Third Parties shall acknowledge NuVenture’s commitment to prevention of slavery and human trafficking. 

The Compliance Team shall have sole authority to interpret, amend, modify, or revise the provisions of this Policy, as and when deemed fit, subject to the approval of the board of directors of the respective NuVenture entity, wherever required under the Applicable Laws. 

Any queries under this Policy can be addressed to the Compliance Team at compliance@NuVenture.com. 

 

Date of Last Revision: 22nd September 2022