Anti-Slavery Policy

4. Our Business

Navarino (UK) Ltd Group is a satellite communications/connectivity provider and developer of advanced technologies and innovative IT solutions. We are addressing the Maritime industry, meeting merchant vessels’ connectivity needs and IT requirements, worldwide.

Our business runs its activities during the standard working hours dictated by the respective Labour legislation of the countries in which we operate.

5. Our Supply Chain

The majority of Navarino (UK) Ltd Group Suppliers are large, well known international companies providing satellite communication services, satellite and maritime hardware equipment, web hosting services, technical services relating to the connectivity, IT Solutions and networks onboard merchant vessels. Navarino Group’s 30 largest suppliers (out a total of 403) account for approximately 80% of the procurement spending and are international organizations located in the UK, Germany, Denmark, USA, the Netherlands, Canada, Norway and Greece.

The remaining 20% of Navarino (UK) Ltd Group’s procurement spending is related to local suppliers for products and/or services that are not considered to be of risk for human trafficking or slavery (such as property owners, computer & computer spare parts procurement, service engineers, consultants, logistics, etc).

6. Policies and Practices

6.1 Corporate Values

Within the Navarino (UK) Ltd Group Corporate Values https://navarino.co.uk/about-us/ we set out the principles to which all employees are expected to adhere and suppliers to advocate in meeting these standards.

Additionally, Navarino (UK) Ltd Group operates a series of policies to mitigate the risk of modern slavery and outlines the measures taken to prevent slavery and human trafficking in its operations and supply chain.

These include Navarino People Handbook (Code of Conduct), Recruitment Policy, Performance Management Policy, and Navarino Competence Library, Health and Safety Policy, Human Rights and Whistleblowing Policy, Anti-Harassment Policy, Anti-Bribery, Anti-Corruption and Anti-Money laundering Policy along with the respective reporting lines, where applicable.

These policies are accessible to all Navarino (UK) Ltd Group stakeholders on our website https://navarino.co.uk/esg/  and are being regularly reviewed and updated when it is required.

6.2 Due Diligence

Navarino (UK) Ltd Group initiatives to identify and mitigate risks currently include:

• We are building long standing relationships with our major suppliers being large, solid international companies with defined and published Anti-Slavery and Human Trafficking Statements and Policies. We maintain a Supplier List with the respective URLs.
• No goods or services considered to be of higher risk for human trafficking or slavery (e.g. agriculture, textiles, construction, entertainment, etc) are procured by Navarino Group.
• Having in place contractual terms that ensure the parties (e.g. suppliers, contractors, resellers, customers) conform to local, European and international laws, while provisioning goods and services in the supply chain.
• Navarino Group Contracts with suppliers indicate that any rights or obligations cannot be sub-contracted to any third party without the written consent of the contracting parties.
• We ensure transparency in our financial and tax related activities by running yearly audits.
• Our legal compliance is consistently related to Employment, Occupational Health and Safety & Wellbeing regulations.
• Our recruitment process is transparent. We perform vetting of new employees that ensure they can confirm their identities and qualifications and they consent to be paid directly into an appropriate, personal bank account.
• We have adopted a Whistleblowing Policy that will ensure any person part of our Company and/or our Supply Chain feel free to raise concerns about potential unlawful acts or practices violating the human rights, without fear of reprisals. Our Whistleblowing Policy can be found at https://navarino.co.uk/wp-content/uploads/2023/12/Whistleblowing-Policy.pdf. The effectiveness of the Whistleblowing Policy will be measured by a) the number of incoming reports and b) the number of the investigated incidents that will be classified as modern slavery and human trafficking practices.
  No incidents were reported during 2023.
• We encourage external stakeholders to report anonymously at whistleblowing@navarino.gr any concerns about noticed incidents of violation of human rights within the supply chain.
  No incidents were reported during 2023.
• We encourage our employees to report any concerns about business partners’, managers’ and other employees’ actions of human rights violation, illegal and unethical behaviors.
  No concerns nor incidents were reported during 2023.
• A Committee consisting of Navarino Group Senior Managers is formed for assessing and handling Reports and proposing measures it deems necessary and appropriate. The Committee consists of the Whistleblowing Reports Receiving and Monitoring Officer (“WRRMO”) acting as President, the Chief People Officer acting as secretary and the Legal Counsel of the Navarino Group, acting as member.
• Regular internal trainings occur with informative material on the definition of modern slavery, the basic principles of the Modern Slavery Act 2015, on occupations, environments, sectors of high risk, on how to identify suspected incidents of modern slavery and human trafficking, how to report incidents of modern slavery and human trafficking within the Company, how to escalate potential slavery and human trafficking issues to relevant parties, and how to support potential victims.
• A Health & Safety Committee was formed in 2021 to regulate H&S issues: identify, evaluate and control hazards, draft and review Safety Policies, plan and organize H&S trainings and drills. On 2023 Navarino Single Member SA was certified according to ISO 45001 Standard by Bureau Veritas.
• A sustainability strategy was formed in 2022 aiming to fully incorporate ESG (Environment- Social – Governance) criteria in business strategy by 2025.
• In the suppliers’ evaluation policy, sustainability related criteria (E-S-G) have been added next to the existing business criteria.
• Navarino developed a due diligence supplier Policy that includes among others specific questions on modern slavery and human rights issues.

6.3 Commitments for 2024

• Continue developing training modules on Modern Slavery and Human trafficking.
• Continue monitoring and responding to changes in legislation on Modern Slavery and Human Trafficking
• Continue to evolve the antislavery and human trafficking policy seeking guidance from available best practices and experts, where possible and appropriate.
• Implement extensive screening process for at least 50% of the Navarino Group suppliers based on the due diligence supplier Policy.

7. Risk Analysis

Whilst the risk of slavery and human trafficking in the Group’s activities and supply chains are low, we acknowledge that there are potentially victims of modern slavery and human trafficking living in some of the geographical areas we operate. However, our key suppliers have been reviewed and found to be in very low risk areas working in sectors that are not considered to be of high risk and with defined and established Anti-Slavery and Human Trafficking Policies in place.

8. Review & Publication

This Statement will be reviewed by the Quality Assurance and Compliance Manager annually or whenever legal, business or other reasons dictate. The QA&C Manager will demonstrate progress and suggest new targets that will be subject to the Board of Directors’ approval.

Once the Statement is approved, it will be published to the Corporate website www.navarino.co.uk, on https://tiscreport.org/ and www.modernslaveryregistry.org within 6 months after 31/12/2023, being the date the financial year ended.

9. Contact

For any questions or for information on the policy outlined in this document, please contact Tom Kyriakopoulos at  tk@navarino.co.uk or at +30 6944 591214.

10. Approval

This Statement was approved by the Board of Directors on 5/3/2024.

Tom Kyriakopoulos (Director)