Anti-Slavery and Human Trafficking

We are committed to improving our practices to combat slavery and human trafficking.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our obligations under applicable law, including the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

Organisation’s structure

We are a global provider of IT consulting and managed services. Our group of companies include Pythian Services Inc. and its subsidiaries Pythian UK Limited, Pythian India Private Limited, Pythian Australia Pty Ltd., and ManageServe (India) Private Limited; and Pythian Services USA Inc. and its subsidiaries Agosto, LLC. and ManageServe, Inc. (collectively, “Pythian”).

Our supply chains

Our supply chains include subcontractors that may assist Pythian in the provision of Services to its customers. In the course of Pythian’s operations, Pythian also uses the services of cloud providers.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk we are developing due diligence procedures that will be incorporated into our Procurement and Vendor Qualification Process, specifically designed to

Identify and assess potential risk areas in our supply chains.
Mitigate the risk of slavery and human trafficking occurring in our supply chains.
Monitor potential risk areas in our supply chains.
Protect whistle blowers.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a Procurement Policy and Vendor Qualification Procedures, which will be enhanced as of 2022 to include due diligence processes for slavery and human trafficking.

We are integrating a dedicated Compliance Office, integrated by Legal, Finance, Human Resources and Security, which will be responsible of ensuring compliance with our Anti-slavery Policy. Any communications relating to compliance with the Modern Slavery Act 2015 or any other applicable modern slavery legislation are received by this Compliance Office at compliance@pythian.com.

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