1. Purpose
NanoDC Incorporated is committed to conducting business ethically and with integrity in all operations and relationships. We take a zero-tolerance approach to modern slavery, forced labor, and human trafficking in any form.
This policy outlines our commitment to preventing slavery and human trafficking within our organization and throughout our supply chain, in accordance with applicable laws including the California Transparency in Supply Chains Act and relevant U.S. federal regulations.
2. Scope
This policy applies to:
- All employees, officers, directors, contractors, and temporary workers
- All suppliers, vendors, partners, and third parties acting on behalf of [Company Name]
- All business activities globally
3. Definitions
For purposes of this policy:
- Modern slavery includes forced labor, bonded labor, child labor, and human trafficking.
- Human trafficking involves the recruitment, harboring, transportation, or obtaining of persons through force, fraud, or coercion for labor or services.
4. Policy Statement
Naondc Inc strictly prohibits:
- Forced, bonded, or involuntary labor
- Child labor in violation of applicable laws
- Human trafficking or exploitation
- Retention of identity documents or wages
- Any form of coercion, abuse, or intimidation
We expect the same standards from all parties doing business with us.
5. Responsibilities
Management
Senior management is responsible for:
- Supporting implementation of this policy
- Ensuring appropriate controls are in place
- Promoting awareness and compliance
Employees
All employees must:
- Act in accordance with this policy
- Report suspected violations
- Complete required compliance training
6. Due Diligence and Risk Management
Nanodc Inc. maintains reasonable procedures to identify and mitigate slavery risks, including:
- Supplier onboarding reviews
- Contractual requirements prohibiting forced labor and trafficking
- Periodic supplier assessments where appropriate
- Risk-based evaluation of high-risk geographies or services
Suppliers may be required to certify compliance with applicable labor laws and this policy.
7. Training and Awareness
Relevant employees receive training on:
- Identifying indicators of modern slavery
- Reporting concerns
- Ethical sourcing expectations
Training is refreshed periodically.
8. Reporting Concerns
Any suspected violations should be reported immediately to:
- Management
- Human Resources
- Compliance or Security leadership
Reports may be made confidentially and without fear of retaliation. Retaliation against individuals who raise concerns in good faith is strictly prohibited.
9. Enforcement
Violations of this policy may result in disciplinary action up to and including termination of employment or business relationships.
Suppliers found in breach may face remediation requirements or termination of contracts.
10. Continuous Improvement
Nanodc Inc.is committed to continuous improvement of its practices and controls to prevent modern slavery and human trafficking and will review this policy periodically.
11. Approval
This policy is approved by executive management and reviewed annually.
- Approved by: Executive Leadership
- Effective Date: 01 January 2026
- Last Review: 01 January 2026