Slavery and Human Trafficking Policy

Slavery and Human Trafficking Policy

Turtlestack is committed to preventing modern slavery and human trafficking in accordance with the Modern Slavery Act 2015. While the nature of our business—developing NXOpen plugins for Siemens NX with limited subcontracting—poses minimal risk, we remain dedicated to ethical business practices.

We do not engage in or tolerate any form of slavery, forced labor, or human trafficking. We expect all subcontractors and business partners to adhere to the same high ethical standards. Any concerns regarding modern slavery will be investigated, and appropriate action will be taken. This policy reflects our commitment to human rights and responsible business conduct.

Modern Slavery Non-Compliance Response Process

1. Identification Any suspicion or evidence of slavery, human trafficking, or forced labor must be reported immediately to [designated person or department].

2. Initial Assessment Gather relevant information and assess the validity of the concern. If necessary, consult external experts or legal advisors.

3. Escalation & Investigation Conduct a confidential internal investigation. Engage with the subcontractor or supplier for clarification and evidence of compliance. If serious concerns persist, escalate the matter to senior management.

4. Corrective Action & Remediation Demand an immediate action plan from the non-compliant party to rectify the issue. If necessary, provide support to victims, including referral to relevant authorities.

5. Termination & Reporting If no satisfactory resolution is reached, consider terminating contracts with the non-compliant party. Report findings to relevant authorities if legal violations are identified. Document all actions taken for compliance and audit purposes.

6. Review & Prevention Conduct a post-incident review to strengthen internal policies. Increase due diligence in supplier vetting and risk assessments. Provide training to employees and subcontractors where necessary.