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Modern Slavery Policy

As an equal opportunities employer MENA Executive Training and it's parent company AQ Services LLC has a zero tolerance to modern slavery and is committed to the rights of our employees and associates. 

 

Below is our Modern Slavery Policy.  

 

Scope 

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This Policy is applicable to every employee including senior management and members of the Board of Directors and Group-entities. The requirements under this Policy also extend to intermediaries, suppliers, service providers, consultants, and all the other supply chain partners who are directly or indirectly doing business with the Company. 

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Modern Slavery have been defined in two terms as below: 

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Forced Labour

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Any work or service that is exacted or exploited from any person under the menace of any penalty, fear, or coercion and to which the person has not offered himself or herself voluntarily or is not as per terms of employment contract. It refers to situations in which persons are coerced to work using violence or intimidation, or more subtle means such as manipulated debt, retention of identity papers or under paying or threats of denunciation to immigration authorities or blocking free movement. 

Exploitation shall include, at a minimum, prostitution of others or other forms of sexual exploitation or the removal of organs, slavery or practices similar to slavery like compensating lesser than others for the same work and output or discriminating on the basis of appearance, color, gender or race. 

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Human Trafficking

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Human trafficking shall mean the recruitment, transportation, transfer, harboring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation. 

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Policy Statements 

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  • • Company has zero tolerance to Modern Slavery in whatever shape and form it may present in. 

  • • The Company prohibits Modern Slavery in all shapes and forms across its group-entities as well as supply chain partners, intermediaries, investment companies, investment managers, service providers, consultants and all the other partners including but not limited to second tier supply chain partners. 

  • • Any contract entered by the Company with supply chain partners, intermediaries, service providers, consultants, investment managers, investee companies and others, requires an explicit clause obliging them to comply with the applicable or equivalent regulations prohibiting Modern Slavery, if they do not have an official Policy on Modern Slavery in line with this Policy. 

  • • The Company prohibits engaging with parties who have been convicted of Modern Slavery by recognized international organization or local legal and regulatory authorities or based on suspicion of violation of this policy. 

  • • The Company neither charges itself nor allows recruitment consultants to charge any recruitment related cost, commission, visa or travel / hotel expenses to the Employees. 

  • • The Company prohibits any ambiguity, misrepresentation, or manipulations whatsoever in making any offer for employment. Offer Letter is designed to bring in clarity, consistency, and transparency in terms of identified job description, compensation break-up, working location, probation period, brief terms of employment etc. 

  • • The terms of notice period in the employment contract are designed to provide fair and equitable protection to the interests of every Employee(s) that allows smooth transition of employment, subject to any regulatory norms. 

  • • Based on the job role and seniority of an employee, in specific situations a non-Compete clause with a reasonable non-compete period in the employment contracts is inserted to protect the interest of the Company from a competing company during the non-compete period operating in the same industry, subject to any regulatory norms. 

  • • The Company does not hold any money deposits or retain or withhold any personal documents, educational certificates, or passport of 

  • • The Company ensures full rights and benefits of Employee(s) as per local labor legislations and duly honors immigration related rules. 

  • • The Company ensures that no Employee’s freedom of movement is regulated, curtailed, or blocked, after duty hours. 

  • • The Company facilitates free movement of Employee(s) within or outside the country as per prior approved leave and travel benefits to ensure non-interruption to business operations, subject to applicable local law and regulation. 

  • • The Company provides a hygienic, healthy, and safe environment for the Employee(s) and allows effective collaboration among colleagues to execute the job efficiently. 

  • • The Company encourages Employee(s) to maintain proper work balance and work within the official duty hours, however, to meet exceptional business exigencies, the Company has a policy to compensate for the extra hours worked. 

  • • The Company prohibits psychological, economical, or violent threats, intimidation, bullying, in violation of which disciplinary action or legal prosecutions are initiated. 

  • • The Company is neutral to appearance, color, gender, race, or origin of Employee(s) in terms of fixing compensation. The Company encourage fair compensation to all Employees and do not target any group or Employee or adopt subtle means to underpay. 

  • • The Company has a pre-determined day for release of monthly salary to pre-approved bank accounts of the Employees every month, as per the payroll cycle and prohibits any withholding or deductions or over-dues in violation of the employment contract, subject to local labour laws. 

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