Escravatura moderna e trabalho forçado

This statement is written in the form required by section 54 of the UK Modern Slavery Act 2015, and it addresses in addition the mandatory criteria of section 16 of the Australian Modern Slavery Act 2018, the duties of the German Lieferkettensorgfaltspflichtengesetz of 16 July 2021, and the due diligence obligations of Directive (EU) 2024/1760 as amended by Directive (EU) 2026/470.

Whether an entity of the group falls within the turnover threshold set by SI 2015/1833 for the United Kingdom, the consolidated revenue threshold of section 5 of the Australian Act, or the employee thresholds of the German and European texts, is determined at the close of each financial year. This statement is published in the same form whether or not a threshold is met in a given year. The German law retains its due diligence duties; its reform removes the annual reporting obligation and refocuses penalties on serious breaches, without lowering the substantive standards according to the German government. It applies until the European directive is transposed, which is due by 26 July 2028, the obligations themselves applying from 26 July 2029.

This statement is submitted to the board of directors for approval and for signature by a director, in accordance with section 54(6) of the Modern Slavery Act 2015; section 13 of the Australian Act requires approval by the principal governing body and signature by a responsible member. The approved statement carries the name of the signing director, the financial year it covers and the date of approval, is linked from a prominent place on the homepage as section 54(7) requires, and is republished for each financial year within six months of its close.

Parousia Group is a privately held technology holding with its registered office at 157 avenue du Livre, Kinshasa – Gombe, Democratic Republic of the Congo, offices in the United States, the United Kingdom and Dubai, and a technical arm, Echad Technologies, in Singapore. It operates through five regional holding companies — Parousia West Africa in Lagos, Parousia East Africa in Nairobi, Parousia Europe in London, Parousia America Inc. in New York and Parousia Middle East in Dubai.

The group operates six solutions: NetVox Intelligence in unified communications and applied artificial intelligence, Global Technology Africa in cloud and platforms, Afrika Plaza in commerce, PAGEXPRESS in logistics, PAGPay in payments, and INTIC in educational technology, which is under construction. What the group buys follows from what those solutions do, and the exposure to forced labour is concentrated in four categories rather than spread evenly across procurement. The Procurement Department maintains the category analysis set out below and reviews it at least once a year.

The group contracts with distributors, integrators and service firms, and rarely with the plant that manufactured the equipment or the agency that recruited the worker. A first-tier supplier may comply with the terms of its contract while the practice at issue occurs two or three tiers below it, in a country the contract does not name. The risk indicators below are those the Procurement Department applies when it scores a category, assesses a supplier or examines a finding.

• •Recruitment fees charged to workers, which turn a wage into a debt and a job into bonded labour. This is the most common entry point into forced labour in electronics assembly, construction and guarding, and it is the indicator the group treats as decisive.
• •Retention of identity documents and passports, restriction on freedom of movement, and accommodation controlled by the employer or the broker.
• •Contract substitution — the terms signed in the country of origin replaced by worse terms on arrival — and wages withheld, deducted or paid late.
• •Excessive overtime presented as voluntary, and penalties for refusing it.
• •State-imposed forced labour in the production of electronics components and their inputs, which is the subject of section 307 of the US Tariff Act of 1930 and of the Uyghur Forced Labor Prevention Act, and which reaches the group through hardware and terminals rather than through any direct purchase.
• •Child labour and forced labour in the artisanal mining of cobalt, tantalum, tin, tungsten and gold. The group has its registered office in the Democratic Republic of the Congo, where this risk is documented, and it is treated as a risk of the group’s own region rather than as a distant one.
• •Subcontracting chains in construction that add a tier for each trade, so that the workers on site are engaged by a party the group has never contracted with.
• •Guarding and cleaning contracts awarded on price, where the margin is taken out of wages and the workforce is supplied by brokers.

The group prohibits forced labour, bonded labour, indentured labour, prison labour imposed as a means of coercion, human trafficking and child labour, in its own operations and in the supply chains that serve them. The prohibition is defined by reference to the instruments of the International Labour Organization listed below, so that it carries the same meaning in each country the group operates in. The Compliance Department owns this statement and the prohibition it states, the Procurement Department applies them to suppliers and to the supply chain, and Human Resources applies them to recruitment in the group’s own entities.

• •Conventions No. 29 and No. 105 on forced labour and the Protocol of 2014, and Conventions No. 138 and No. 182 on the minimum age and on the worst forms of child labour, are the reference standards.
• •The employer pays principle: no worker pays a fee to obtain work with the group or with a supplier acting for it, at any stage of recruitment, and fees already paid are reimbursed rather than merely prohibited for the future.
• •No identity document is retained, no deposit is taken, and no worker is prevented from leaving their employment on reasonable notice.
• •Every worker has a written contract in a language they understand, stating pay, hours and the terms of accommodation where accommodation is provided.
• •Freedom of association and the right to collective bargaining are respected, and where local law restricts them the group does not rely on that restriction to obstruct workers organising.
• •Recruitment in the group’s own entities is conducted by Human Resources without the use of an intermediary that charges a fee to a worker, and a labour provider engaged for the group is bound by the terms set out below.
• •Any person working under the supervision or direction of a contractor, subcontractor or supplier of the group may use the reporting channel in the whistleblowing policy, on the same protection against retaliation as an employee.

Due diligence here means the process described by the UN Guiding Principles and by the OECD Guidance: identify the risk, act on it, track whether the action worked, and account for it publicly. The Procurement Department conducts that process for the supply chain, with the Compliance Department, and it comprises the steps below.

• •Mapping of first-tier suppliers by category, country of delivery and country of manufacture where it is known, starting with the four high-exposure categories rather than with the whole vendor list.
• •Risk scoring by category and country, using the risk indicators set out above and the OECD guidance on minerals from conflict-affected and high-risk areas, rather than a supplier self-declaration alone.
• •The contractual terms required of suppliers below, imposed on new contracts and on renewals in the high-exposure categories first.
• •A grievance route that reaches workers rather than only counterparties: the whistleblowing channel operated by the Legal Department is open to the workforce of contractors, subcontractors and suppliers, and this statement is the notice of it.
• •Escalation and remediation as the first response to a finding, with termination reserved for a supplier that refuses to remediate, so that the leverage needed to obtain redress for the worker is preserved.

Supplier assessment is carried out by the Procurement Department, beginning with the four high-exposure categories, and each assessment records what was examined, the method used — documentary review, site visit or worker interview — the party that carried it out, and the findings. The right of inspection required by the contract terms below, including unannounced inspection and access to workers, is the basis on which an on-site assessment is conducted. Findings are reported to the Compliance Department and are accounted for in the next statement.

The following terms are required by the Procurement Department in new supplier contracts and at renewal, starting with the categories marked high in the table above. They are drafted as obligations with consequences rather than as declarations of principle.

• •Prohibition of forced, bonded, indentured and child labour and of human trafficking, defined by reference to the ILO conventions listed above.
• •The employer pays principle, with an express obligation to reimburse any recruitment fee already borne by a worker, whoever collected it.
• •Prohibition of retaining identity documents, of charging deposits, and of restricting the freedom of movement of workers.
• •A written contract for every worker in a language they understand, wages paid directly to the worker on time and without unlawful deduction, and working time within the applicable legal limits.
• •Notification to the group of any credible allegation of forced or child labour in the operations of the supplier or its own suppliers, within five working days of the supplier becoming aware of it.
• •A right of information about lower-tier suppliers for the categories marked high, and flow-down of these terms to subcontractors, with the supplier answerable for their compliance.
• •A right of inspection, including unannounced inspection and access to workers, exercisable by the group or by a party it appoints.
• •An obligation to co-operate in remediation, including reimbursement of fees, repayment of withheld wages and repatriation where a worker asks for it.
• •Termination for a supplier that refuses to remediate or that conceals a finding, and no clause of a group contract restricts a worker or a supplier employee from making a report.

Contracts signed before this clause set was adopted remain in force on their original terms and are brought within it at renewal or by amendment, the high-exposure categories first. The Procurement Department records, for each of those categories, the share of spend covered by the clause set, and that coverage is reported in the next statement.

On a credible finding, the group first acts to remove the immediate harm to the worker: recovery of retained documents, reimbursement of recruitment fees and payment of withheld wages by the party that owes them, and safe accommodation or repatriation where the worker asks for it. The commercial relationship is dealt with afterwards.

A supplier that co-operates is kept under a corrective plan with dates, which the Procurement Department follows to completion. A supplier that conceals a case or refuses to remediate is terminated. Where the facts suggest an offence, they are reported to the competent authority of the jurisdiction concerned; no term of a group contract prevents that report, and confidentiality clauses are not applied to it.

Training is directed at the roles that can identify the risk in the course of their work: the staff who select suppliers, negotiate service contracts, receive deliveries, supervise sites, and hire. The Compliance Department sets the content and delivers it with the Procurement Department and Human Resources, and it covers the following.

• •The ILO indicators of forced labour, and how each one appears in a quotation, a site visit or a payroll rather than in a definition.
• •Recruitment through brokers: the questions to ask, the documents to request, and the answers that should stop a contract.
• •The clause set required of suppliers, what it obliges the supplier to do, and how a breach is escalated.
• •How to make a report, and the protection that attaches to it under the whistleblowing policy.

Attendance is recorded by the Compliance Department, and the record is produced to a client, an auditor or a competent authority on request. The completion of the training by the roles listed above is one of the indicators reported on below.

Section 54(5)(e) of the UK Act asks an organisation to measure its effectiveness against appropriate performance indicators, and section 16(1)(e) of the Australian Act asks how the entity assesses the effectiveness of its actions. The indicators below are those against which the group measures the effect of the actions described in this statement. Each is stated with what it measures and with the function that measures it, and the results are reported in the statement published for each financial year.

• •Complete the mapping of first-tier suppliers in the four high-exposure categories, and record the country of manufacture where the supplier states it.
• •Carry out the risk assessment on that mapping, and account for its findings in the next statement, including the categories where the facts could not be established.
• •Extend the clause set required of suppliers to contracts predating it, at renewal or by amendment.
• •Deliver the training described above to procurement, site supervision and hiring staff, and record completion.
• •Establish the baseline for each indicator listed above and report against it for each financial year.
• •Where an entity of the group falls within the Australian Act, file the statement with the register under section 14.