ACT Policy Against Child Labor, Forced Labor & Human Trafficking

Advanced Call Center Technologies (“ACT” or the “Company”) is committed to ensuring that the Company and its Vendors/Subcontractors (“Vendors”) do not use Child labor, Forced Labor or engage in Human Trafficking.

ACT ensures that working conditions are safe, that workers are treated with respect and dignity as understood by the international community, and business operations are environmentally responsible and conducted ethically. Both ACT and its vendors are expected to honor this commitment

“Forced Labor” means coerced labor, involuntary servitude, peonage or indentured labor, involuntary prison labor, slavery, human trafficking or sex trafficking, including but not limited to transporting, harboring, recruiting, or transferring persons by means of threat (including but not limited to threat of harm or physical restraints, or threat of abuse of legal process), force, coercion, abduction or fraud.

ACT expressly prohibits its vendors from using, engaging in or facilitating Forced Labor of any kind. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker. Vendors unwilling to meet these requirements may be ineligible for ACT approved vendor status.

ACT and its approved vendors are required to conduct due diligence on the presence of Forced Labor in their supply chain and to comply with this Policy.  As such, ACT and its vendors shall:

• Comply with applicable US and international laws prohibiting Forced Labor.

• Uphold the human rights of workers and treat them with dignity and respect.

• Ensure that all work is voluntary and workers are free to terminate their employment.

• Disclose to workers all terms and conditions of employment, and any hazardous nature of work, location of work, grievance process, and provide information about applicable laws and regulations prohibiting Forced Labor.

• Employ workers on the basis of their ability to do the job.

• Ensure all workers meet the applicable minimum legal age requirement.

• Set work hours, wages and over-time pay in compliance with all applicable laws.

• Pay workers at least the minimum legal wage or a wage that meets local industry standards, whichever is greater, and comply with legally mandated benefits.

• Ensure workers are aware of Forced Labor prohibitions and the actions that will be taken against the employees for violations, including posting relevant information on the Supplier’s web-site, at work places, and, when such posting are impracticable, provide such information to workers in writing.

• Discipline workers and suppliers who use or facilitate Forced Labor.

• Provide workers an opportunity to report suspected violations without a fear of retaliation.

ACT and its vendors shall not:

• Unreasonably restrict workers’ freedom of movement in the company facilities.

• Hold or otherwise destroy, conceal, confiscate or deny access by workers to their identity or immigration documents, such as government-issued identification, passports or work permits, unless such holdings are required by law.

• Use recruiters or staffing agencies that do not comply with applicable labor laws, or charge workers any recruitment fees.

• Engage in or permit corporal punishment, threats of violence, mental or physical coercion, verbal abuse of workers or other forms of harassment whether based on gender, race, color, religion, ethnicity, age, sexual orientation, national origin, disability, or any other legally protected characteristic.

• Use child labor. A “child” means any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country or locations, whichever is greatest.

• Discriminate on the basis of race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy or maternity, religion, political affiliation, covered veteran status or marital status.

ACT reserves the right to audit its vendor’s compliance with this Policy. The vendor will allow ACT or any of its representatives or agents access to its facilities and all relevant records. The vendor will accommodate ACT’s requests to access the vendor’s records and facilities when ACT’s business requires immediate access to the same.  Vendor also agrees to cooperate with ACT to investigate any Forced Labor allegations against ACT or any of ACT’s customers.

To mitigate Forced Labor issues, this Policy also applies to the vendor’s sub contractor(s). This Policy shall be flowed down to all sub-tier subcontractors, including staffing agencies and other providers of contract labor. The vendor is fully responsible for ensuring compliance by any such sub-contractor(s).

Any employee who becomes aware of a violation of this Policy, or who has questions about the Policy, should contact the ACT Compliance Officer or VP of Human Resources. ACT expects employees to report any witnessed behavior not deemed to be consistent with our Company Policy immediately. In addition, an employee may anonymously call our Company Hotline at 423-262-1499 to leave a message or e-mail at http://intranet.acttoday.com/Suggestion. Concerns will be investigated promptly.