Slavery and Human Trafficking Statement
2016-2017 GENBAND Statement on the Prevention of Slavery and Human Trafficking
GENBAND works in an energetic global telecommunications industry where the pace is fast and change is constant. But, there are some things that don’t change at GENBAND—our commitment to doing business honestly, ethically, and with respect for people. It is to this end that GENBAND has implemented this Statement on the Prevention of Slavery and Human Trafficking, which mirrors the anti-slavery and anti-human trafficking principles embodied in the Company’s employee Code of Business Conduct and Ethics and its Supplier Code of Conduct.
It has always been paramount to our way of doing business at GENBAND to comply with applicable law and to act with the utmost integrity, honesty, and transparency. GENBAND is committed to acting responsibly in all of our business dealings to ensure that we comply with applicable national and international legislation and industry standards, including laws and standards against slavery and human trafficking. GENBAND will forgo business opportunities rather than act in an unlawful, unethical, or inhumane manner. Preserving an ethical workplace and supply chain that respects human rights is critical to our long-term success as a leading global telecommunications company.
At GENBAND, the message for each GENBAND employee and supplier is clear: Any success that is not achieved lawfully and ethically is no success at all. At GENBAND, we obey applicable law—including laws against slavery and human trafficking—and strive to hold ourselves to the highest ethical and legal standards, and we expect the same of all of our suppliers.
GENBAND’s Business Structure and Supply Chain Relationships
Founded in 1999, GENBAND is a global leader in real-time communications software solutions for service providers, enterprises, independent software vendors, systems integrators and developers in over 80 countries across the Americas, Europe, the Middle East and Africa, and throughout the Asia Pacific region. GENBAND is headquartered in Plano, Texas and has operations, R&D and resources around the globe that provide world-class support and services for its vast customer base.
As of February 2017, GENBAND directly employs over 1300 skilled employees in 26 different countries, and is an indirect source of work for many workers through its global supply chain relationships in, among other countries, Turkey, Mexico and India.
GENBAND’s business is real-time communications. It is not a manufacturer (so does not own or operate factories or production plants) nor a handler of raw materials or commodities (so does not own or operate processing plants). However, GENBAND’s business relies on suppliers and complex third-party commercial relationships.
GENBAND’s Policies against Slavery and Human Trafficking
GENBAND’s commitment to complying with and supporting laws and moral standards that prohibit slavery and human trafficking is evidenced by the human rights and labor policies contained in its employee Code of Business Conduct and Ethics and its Supplier Code of Conduct. These policies are rooted in the law and internationally recognized standards including, for example, the Electronic Industry Citizenship Coalition Code of Conduct, the United Nations’ Universal Declaration of Human Rights, and the International Labor Organization’s International Labor Standards.
While GENBAND’s policies reflect the law and global standards, they also reflect the unequivocal expectation of the Company’s leadership that its employees and suppliers support it compliance with anti-slavery and human trafficking laws.
GENBAND’s Supplier Code of Conduct directly addresses the labor rights issues associated with slavery and human trafficking. For example, the Supplier Code of Conduct states that:
- Forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery or trafficking of persons may not be used either by any supplier or its contractors, suppliers or subcontractors. This prohibition includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services.
- There shall be no unreasonable restrictions imposed by suppliers on their workers’ freedom of movement in or beyond supplier facilities.
- All work performed must be voluntary and workers must be free to leave work at any time or terminate their employment.
- Suppliers may not hold or otherwise destroy, conceal, confiscate or deny access by workers to workers’ identity or immigration documents, such as government-issued identification, passports or work permits, unless the holding of work permits is required by law.
- Workers may not be required to pay suppliers or agents’ recruitment fees or other aggregate fees in excess of one month’s salary. All fees charged to workers must be disclosed to GENBAND and fees in excess of one month’s salary must be returned to the worker.
Training Regarding GENBAND’s Anti- Slavery and Human Trafficking Policies
GENBAND has developed measures to ensure that its prohibition of slavery and human trafficking extends beyond its policy documents.
During the new hire onboarding process, individuals wishing to join GENBAND as an employee must certify that they have read the employee Code of Business Conduct and Ethics, and confirm that they agree to abide by it policies, including its policy against forced labor. Every supplier who wants to do work for GENBAND is required to first sign up to the Company’s Supplier Code of Conduct. GENBAND requires its current employees and top 50 contract manufacturer, OEM, and component suppliers (selected based on annual spend, quality issues, and date of last audit) to complete an annual Code review and re-certification process. Completion of this annual re-certification process is a term and condition of the targeted participants’ continued relationship with GENBAND, in accordance with applicable law.
GENBAND provides suppliers and employees with several avenues to report to the Company any suspected and/or actual violations of GENBAND’s policies against slavery and human trafficking. For example, GENBAND has published employee reporting options—which include an anonymous hotline in various countries—in the employee Code of Conduct and on its intranet website. The Legal Department, frequently reminds employees of the Company’s reporting options during employee online training sessions and all employee email alerts. Suppliers are encouraged to report questionable conduct related to any topic covered in the Supplier Code—including slavery and human trafficking—to GENBAND’s Legal Department. Since January 1, 2016 to date, GENBAND has not received any employee or supplier reports alleging slavery or human trafficking in GENBAND’s workplace or supply chain.
GENBAND’s supply chain audit team has been trained to conduct GENBAND’s specialized Corporate Social Responsibility (“CSR”) audit, which includes a modern slavery and human trafficking component.
In 2017, GENBAND aims to provide key supply chain leaders and auditors with focused training on slavery and human trafficking.
GENBAND’s Audit Practices in Relation to Slavery and Human Trafficking
GENBAND screens prospective suppliers for criminal conduct—such as slavery and human trafficking—using World-Check Intelligence, a risk intelligence data base. The Company will screen a current supplier using World-Check Intelligence if it reasonably believes that the supplier is in violation of applicable law. GENBAND will reject a prospective or current supplier if it cannot meet GENBAND’s corporate social responsibility requirements and/or has been officially sanctioned for human trafficking or slavery violations; provided that, GENBAND will consider engaging with, or continuing to engage with, a supplier that has been convicted of slavery and human trafficking if the supplier can demonstrate to the satisfaction of GENBAND’s supply chain leadership that it has engaged in effective remediation efforts to address the concerns.
All North America GENBAND employees are subject to an extensive criminal background check during the hiring phase as a condition of employment with the Company. Current employees may be subject to a criminal background check during the employment relationship should circumstances so require. GENBAND uses a third-party background check provider, EBI Inc., to run its employee background checks. Subject to applicable law, GENBAND will not confirm or continue employment of an individual who has been convicted for crimes related to slavery and human trafficking.
GENBAND conducts regular onsite corporate social responsibility (“CSR”) audits of its contract manufacturer, OEM and components suppliers in accordance with a CSR audit program which was developed for GENBAND by epi Consultants, a leader in CSR program management. Suppliers are selected by GENBAND for audit based on a number of factors including, annual spend and quality concerns. GENBAND’s CSR audits evaluate supplier compliance with, among other issues, GENBAND’s standards against slavery and human trafficking, and include onsite facility walk-throughs by GENBAND auditors as well as supplier interviews and questionnaires designed to uncover slavery and human trafficking concerns. In 2016, GENBAND audited four suppliers, and found no indications of slavery or human trafficking.
In 2017-2018, GENBAND aims to include software suppliers in its CSR audit process.
GENBAND Chairman of the Board and CEO