Policy Against Trafficking

Policy Against Trafficking in Persons and Slavery

Grøn Sky has developed and operates the platform CopenCloud. This policy applies to both platform and company.

Grøn Sky is committed to a work environment that is free from human trafficking and slavery, which for purposes of this policy, includes forced labor and unlawful child labor. Grøn Sky will not tolerate or condone human trafficking or slavery in any part of our organization. This policy is consistent with Grøn Sky’s Code of Ethics and Business Conduct and our core values to protect and advance human dignity and human rights in our global business practices.

Grøn Sky employees, contractors, subcontractors, vendors, suppliers, partners and others through whom Grøn Sky conducts business must avoid complicity in any practice that constitutes trafficking in persons or slavery.

Scope

This Policy applies to all personnel employed by or engaged to provide services to Grøn Sky, including, but not limited to, Grøn Sky’s employees, officers, temporary employees, contingent workers (including agency workers), casual staff, and independent contractors (for ease of reference throughout this Policy, “employees”).

Every Grøn Sky employee is responsible for reading, understanding and complying with this Policy.

Grøn Sky managers are responsible for ensuring that employees who report to them, directly or indirectly, comply with this Policy and complete any certification or training required of them. If you have any questions or concerns relating to this Policy, or If you learn of any conduct that you believe may violate this Policy, report it immediately by any of the means listed under the heading “Policy Compliance” below.

Policy statement

Grøn Sky prohibits trafficking in persons and slavery. Grøn Sky employees, contractors, subcontractors, vendors, suppliers, partners and others through whom Grøn Sky conducts business must not engage in any practice that constitutes trafficking in persons or slavery. This includes, but is not limited to, the following activities:

Engaging in any form of trafficking in persons;
Procuring commercial sex acts;
Using forced labor in the performance of any work;
Destroying, concealing, confiscating, or otherwise denying access by an individual to the individual’s identity or immigration documents, such as
passports or drivers’ licenses, regardless of issuing authority;
Using misleading or fraudulent practices during the recruitment of candidates or offering of employment/contract positions; such as failing to disclose, in a format and language accessible to the potential candidate, basic information or making material misrepresentations during the recruitment of candidates regarding the key terms and conditions, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if provided by Grøn Sky), any significant cost to be charged to the candidate, and, if applicable, the hazardous nature of the work;
Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
Charging applicants/candidates recruitment fees;
If required by law or contract, failing to provide return transportation or failing to pay for the cost of return transportation upon the end of employment;
If required by law or contract, failing to provide or arrange housing that meets the host country housing and safety standards; or
If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing.

Grøn Sky has undertaken actions and is committed to maintaining and improving its systems and processes, to eradicate human trafficking and slavery in its cloud infrastructure supply chain. Grøn Sky requires its cloud infrastructure supply chain suppliers to observe all applicable laws and conduct business in an ethical and responsible manner. Grøn Sky has adopted the Responsible Business Alliance (RBA) Code of Conduct (formerly the Electronic Industry Citizenship Coalition Code of Conduct), which prohibits the use of forced, bonded, indentured or involuntary prison labor.

Grøn Sky continues to verify, evaluate, promote awareness about, and address risks associated with forced labor and human trafficking in its cloud infrastructure supply chain. Examples of actions undertaken include the following:

Evaluating and addressing supply chain risks in Oracle Cloud Infrastructure

Oracle provides 95% in Grøn Sky’s supply chain. Oracle has incorporated by reference the RBA Code of Conduct into its standard direct hardware supply chain supplier agreements. Oracle also participates in industry efforts to increase awareness of human trafficking and to implement RBA programs, including the Responsible Labor Initiative (RLI).

Auditing suppliers at Oracle

Oracle audits its direct hardware supply chain suppliers based on the RBA Code of Conduct and also reviews the audit results for these suppliers.

Supplier certification at Oracle

Oracle ensures that direct hardware supply chain suppliers certify to the best of their knowledge that the materials they incorporate into products were generated in compliance with applicable anti- slavery and human trafficking laws.

Accountability standards

Grøn Sky upholds accountability standards and procedures for employees and cloud infrastructure supply chain suppliers who fail to meet Grøn Sky’s business conduct requirements.

Training

Grøn Sky provides training on human trafficking and slavery issues to employees that directly manage the supply chain.

Investigations and audits

Grøn Sky will perform investigations and audits to verify that business is being conducted in compliance with this Policy. All Grøn Sky employees and third parties through whom Grøn Sky conducts business are required to fully and promptly

cooperate with Grøn Sky’s internal and external auditors and investigators, and must respond fully and truthfully to their questions, requests for information, and documents. Any failure by an employee to completely cooperate, or any action to hinder an investigation or audit, including for example, hiding or destroying any information or documentation, providing false answers or false information, or deleting email or other documents, may be grounds for disciplinary action, up to and including termination, subject to applicable law.

Policy compliance

Report any conduct that you believe to be a violation of this Policy, either directly to a member of the Compliance and Ethics Organization, to the Grøn Sky Legal Department, or to Grøn Sky’s CEO.

Any violation of this Policy may be grounds for disciplinary action, up to and including termination, subject to applicable law. Violation of applicable laws may also result in criminal prosecution of responsible individuals