NISH Tech BV is committed to acting ethically and appropriately in all business operations and relationships, and to preventing modern slavery and human trafficking in our supply chains. We take serious note of the Belgian legal framework prohibiting forced labor, servitude and human trafficking (e.g., Law of 4 August 1996 on the well‑being of workers in the performance of their work, criminal code provisions such as article 433 quinquies for forced labor) and expect our suppliers, subcontractors and business partners to adhere to the same standards. We require transparency in our business, constant vigilance in our operations, and continuous improvement in our practices.
Scope
This policy applies to:
- All employees of NISH Tech BV, whether permanent, fixed-term, part-time, temporary, or agency
- All contractors, suppliers, subcontractors, agents and other business partners and intermediaries of NISH Tech BV
- All operations of NISH Tech BV in Belgium and any other country where we operate or procure goods and services
- All supply chains and associated services; goods and services procured directly or indirectly
Legal & Regulatory Framework (Belgium & Europe)
Key legal references include:
- Belgian Criminal Code – Forced labor and servitude offences (e.g., article 433 quinquies)
- Belgian laws and regulatory measures on human trafficking and labor exploitation
- European Union reporting obligations on sustainability, supply-chain transparency and non-financial information (e.g., Corporate Sustainability Reporting Directive (CSRD), transposed into Belgian law)
- Belgian legislative measures on subcontracting chain liability and right to work for third-country nationals (especially relevant where labor exploitation might occur)
Definitions
- Modern slavery: A term covering slavery, servitude, forced labor, human trafficking, and other similar forms of exploitation.
- Human trafficking: The recruitment, transport, harboring or receipt of persons by means of threat, force or coercion for the purpose of exploitation.
- Supply chain: The network of suppliers, subcontractors and business partners through which NISH Tech BV obtains goods and services.
- High-risk area: Any part of the supply chain or geography where the likelihood of forced labor or human trafficking is elevated (e.g., low-wage subcontracting, migrant labor, informal employment).
Responsibilities
Board / Senior Management
- Approve this policy and allocate sufficient resources for its implementation.
- Review annual reports on modern slavery, human trafficking and supply-chain due diligence.
- Ensure this policy is communicated and embedded in the company culture.
Procurement / Supply Chain Management
- Identify, assess and monitor high-risk suppliers and subcontractors.
- Ensure supplier contracts contain appropriate clauses regarding modern slavery and human trafficking.
- Undertake due diligence on new and existing suppliers.
- Take corrective action or terminate relationships where violations occur.
Employees
- Understand and comply with this policy.
- Report any concerns or potential violations in good faith.
- Cooperate with investigations and training programs.
Suppliers, Contractors & Partners
- Commit to this policy and the standards set by NISH Tech BV.
- Provide transparency and information required for due diligence.
- Allow audits/inspections when requested.
- Address identified issues in a timely and effective manner.
Risk Assessment & Due Diligence
NISH Tech BV will:
- Conduct a risk-based assessment of our operations, locations, procurement categories and supply chains to identify areas vulnerable to modern slavery and human trafficking.
- Require high-risk suppliers to complete questionnaires, provide documentation of labor practices, and accept audits.
- Engage with suppliers where risk is identified to remediate issues or, if necessary, exit the relationship.
- Map key parts of our supply chain annually and update as necessary.
- Review and update our policies and practices considering new risks, legal developments (e.g., chain liability measures) and lessons learned.
Supplier & Contractual Terms
- All contracts with suppliers, service providers and subcontractors shall incorporate language prohibiting forced labor, exploitative practices and human trafficking.
- NISH Tech BV reserves the right to audit and inspect supplier labor practices.
- Failure to comply may result in termination of contract, financial sanction and/or referral to authorities.
Reporting, Monitoring & Transparency
- Where required under applicable Belgian or EU law, NISH Tech BV will publish an annual modern slavery statement.
- We will maintain records of risk assessments, supplier audits, remediation actions, training, and incident reports.
- We will monitor performance through key indicators (number of supplier assessments, incidents, corrective actions, etc.).
- NISH Tech BV will review this policy at least once annually or when material changes occur.
Training & Awareness
- Provide training and awareness to employees (particularly procurement, supply-chain and senior staff) on modern slavery risks, indicators and reporting mechanisms.
- Supply chain partners will be informed of NISH Tech BV’s expectations and this policy’s provisions.
- Training contents shall be reviewed periodically and updated to reflect emerging risks.
Whistleblowing & Grievance Mechanism
- Establish and maintain secure channels for employees, suppliers, subcontractors and third parties to report concerns regarding modern slavery, human trafficking and exploitation.
- Ensure protection from retaliation for all good-faith reports.
- Investigations will be handled promptly, confidentially and impartially.
- Reports may also be submitted externally to the competent authorities (e.g., SIOD – Social Fraud Reporting Point) if internal mechanisms are not appropriate.
Remediation & Corrective Action
- If a violation of this policy is identified, NISH Tech BV will take appropriate action, including but not limited to:
- Immediate investigation and, where relevant, suspension of supply-chain relationship;
- Engagement with suppliers to develop a remediation plan;
- Termination of relationship if remediation is inadequate or risk remains.
- Victims of exploitation will be treated respectfully and provided with appropriate support.
Review & Continuous Improvement
- This policy will be reviewed annually and updated as required by changes in legislation, business activities or identified risks.
- Senior management will receive regular reports on performance, issues and improvement actions.
- Feedback from employees, suppliers and other stakeholders will be used to enhance our approach.
Reviewed on : 02-Jan-2023