Collectia Group Anti-Slavery Policy

Collectia Group

Collectia Group is a debt collection agency with activities in Denmark, Sweden, Norway, and Germany. Collectia Group sources services primarily from local suppliers in the countries where the Group is present. Due to the nature of the business, suppliers are few and deliver either services, leasing equipment, office equipment/supplies or employee-related services. Even though the risks associated with suppliers are viewed as low given their nature and location in Europe, Collectia Group is still very attentive that the suppliers maintain high standards in terms of CSR matters. The Collectia Group Anti-Slavery Policy should be seen in this context.

Policy objective

This policy supports our commitment to limiting the risk of modern slavery occurring within Collectia Group or any of its supply chains or business relationships.

This policy applies to all persons working for, or on behalf of, Collectia Group, in any capacity, including employees, directors, officers, agency workers, contractors, consultants, volunteers, interns, and any other third party representative.

We expect all who have or seek to have, a business relationship with Collectia Group to familiarize themselves with this policy and to act in a way that is consistent with its values at all times.

We will only do business with organizations who we believe fully comply with this policy, or those who are taking verifiable steps towards compliance.

This policy will be used to underpin and inform any statement on slavery and human trafficking that we are required to produce, further to the transparency in supply chain requirements of Section 54 of the Modern Slavery Act 2015 (MSA).

Modern slavery: What do we mean?

Modern slavery is a complex and multi-faceted problem that can take many forms. The MSA covers four key criminal activities:

1. Slavery: where ownership is exercised over an individual;
2. Forced and compulsory labor: all work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty;
3. Servitude: involves the obligation to provide service imposed by coercion; and
4. Human trafficking: involves arranging or facilitating the travel of another with a view to exploiting them.

Other forms of modern slavery, which we will not tolerate, but are not specifically referenced in the MSA include, but are not limited to, child labor. Whilst not always illegal in the jurisdiction in which it takes place, child labor involves the employment of children that is exploitative, or is likely to be hazardous to, or interferes with, a child’s education, physical and mental health, wellbeing, or social development.

All forms of modern slavery have in common the deprivation of a person’s liberty by another in order to exploit them for commercial or personal gain and amount to a violation of an individual’s human rights.

Embedding our anti-slavery policy in practice

To underpin our policy commitments, we are in the process of implementing the following measures over the course of the financial year:

• We will prepare and conduct risk assessments to determine which parts of our own business and which of our supply chains are most at risk from modern slavery,
• Where appropriate, as informed by our risk assessment, we will engage directly with suppliers in respect of our anti-slavery policy in order to gain a proper understanding of the measures they have in place to ensure that modern slavery is not occurring within their own businesses,
• An investigation into compliance with the anti-slavery policy will be an integral part of future due diligence processes if Collectia Group decides to take part in M&A processes; and
• Collectia Group targets zero incidents in respect of both persons working directly for Collectia Group and anyone else who wishes to establish or maintain a business relationship. We will measure this by counting reported incidents that should be reported to the Compliance Director (Currently the Group CFO).

Responsibility for this policy

The Board of Directors has overall responsibility for this policy and in ensuring that the Company complies with all its legal and ethical obligations.

The Compliance Director (Currently the Group CFO) will have the day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place.

All line managers are responsible for ensuring that those reporting directly to them comply with the provisions of this policy in the day-to-day performance of their roles.

Communication and employee awareness training

The Compliance Director (Currently the Group CFO) will ensure that relevant staff receives adequate training on this policy and any supporting processes applicable to their role.

In addition, high-risk staff (including sourcing personnel) will receive training (will be communicated to and be in receipt of this policy) on the broader issues of modern slavery so as to help them in understanding the extent of the problem and then identify individuals/areas of the business that may be at risk from practices of modern slavery.

Breaches of this policy

Any breaches of this policy will be taken seriously and dealt with on a case by case basis.

The breach of this policy by an employee, director, or officer of the Company may lead to disciplinary action being taken in accordance with our disciplinary procedure. Serious breaches may be regarded as gross misconduct and may lead to immediate dismissal further to our disciplinary procedure.

Everybody to whom this policy applies will be expected to co-operate to the fullest extent possible in any investigation into suspected breaches of this policy or any related processes or procedures.

If any part of this policy is unclear, clarification should be sought from the Compliance Director (Currently the Group CFO), emailing mh@collectia.dk.

Status of this policy

This Anti-slavery policy will be reviewed by the Company’s board of directors on an annual basis.

This policy does not give contractual rights to Company employees and we reserve the right to alter any of its terms at any time. We will notify applicable parties in writing of any changes which may affect them.

Approved by the board.

Please contact mh@collectia.dk for an authorized signed copy.