Published July 1, 2020

Naviga is committed to limiting the risk of modern slavery occurring within its own business, infiltrating its supply chains or through any other business relationship. While Naviga operates in a sector which is at relatively low risk of slavery, unlawful child labor or human trafficking existing within the business and it considers its main suppliers to be at low risk of engaging in practices of modern slavery and human trafficking, Naviga remains committed to prevent the occurrence of any such practices.

The policy applies to all persons working for or on behalf of Naviga, in any capacity, including employees, directors, officers, contractors, consultants and any other third-party representative.

Naviga expects all who have, or seek to have, a business relationship with Naviga to familiarize themselves with this policy and to act in a way that is consistent with its values.

Naviga will only do business with organizations who fully comply with this policy or those who are taking verifiable steps towards compliance. This policy does not form part of any employee's contract of employment and Naviga may amend it at any time.

Responsibility for This Policy

The Chief Executive Officer has overall responsibility for this policy.

Naviga’s Director of Human Resources has the primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring their staff understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

Compliance with this policy

Everyone working for Naviga is responsible for preventing, detecting and reporting modern slavery if it is encountered.

If anyone becomes aware of or suspects that modern slavery is taking place, they must immediately notify Naviga’s Director of Human Resources. This applies whether or not the suspected slavery involves Naviga or one of its third-party suppliers.

Naviga encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

Communication and Awareness

All staff will be notified of this policy on joining and receive training as appropriate from time to time.
Managers will ensure that relevant colleagues receive adequate training on this policy and any supporting processes applicable to their role.

Breaches of This Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for
misconduct or gross misconduct. We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.

If any part of this policy is unclear, clarification should be sought from Naviga’s Director of Human Resources

Status of This Policy

This Anti-Slavery Policy will be reviewed by Naviga on a regular basis.

Scott Roessler
Chief Executive Officer