Modern Slavery and Human Trafficking Transparency Statement

April 2019

This is the Modern Slavery Act annual statement for Graebel Companies Inc., Graebel UK Centre Limited and Graebel Global Client Services Limited and all their subsidiaries (“Graebel”) made pursuant to the provisions of section 54 of the Modern Slavery Act 2015 for the year ended 31 December 2018.

Graebel is committed to ensuring that slavery or human trafficking does not exist in any part of our business or in our supply chain; and believes human rights are to be protected and respected to allow societies, economies and businesses to grow and thrive. Respect for human rights is fundamental to our commitment to ethical business conduct.

This statement of the steps Graebel has taken, including those taken during the financial year, is in an effort to ensure slavery and human trafficking does not take place in any of our supply chains or in any part of our business. Graebel also publishes a Human Rights and Labour Policy, which states its commitment to human rights within the international sphere of our influence, and prohibition on child labour, including bonded, indentured and slave labour.

OUR BUSINESS
Graebel’s business is comprised of freight forwarding and global relocation services arrangements to individuals and entities. We respect and acknowledge internationally recognized human rights principles. Within Graebel and throughout our supply chain, we are committed to treating people with dignity and respect.

We work within a large, diverse value chain of business partners and stakeholders. We recognize that each entity in this chain has its own independent duty to respect human rights. We expect our business partners and stakeholders to adhere to ethical business conduct consistent with our own, and are committed to working with them to fulfil this common goal.

SUPPLIER COMPLIANCE
Graebel recognizes the importance of maintaining both visibility and transparency within its supply chain in order to continue to protect those who work within it from potential abuse and exploitation and to this end, we take great care in selecting our business partners.

Our policy in respect of slavery and human trafficking is to eliminate it both from our business and from our supply chain. Graebel’s suppliers are required to confirm signed acceptance and compliance with our Code of Business Conduct and Ethics. Notwithstanding this requirement, Graebel’s suppliers often have their own complex supply chains and consequently, it is not possible for us to directly monitor or control the working conditions of each individual supplier. However, we are committed to reducing supply chain complexity so that any vulnerabilities can be more easily identified and addressed through a comprehensive risk-based assessment.

Any supplier breaches uncovered via audit or any other means will be investigated and, where possible, remedied. Repeat breaches or those that cannot be remedied may result in the immediate termination of the relevant supplier.

Any breaches of our policies, applicable laws or regulations by the supplier entitle Graebel to terminate the supplier’s contract.

DUE DILIGENCE PROCESS
As part of the supplier onboarding process, the majority of suppliers are required to complete the Customs-Trade Partnership Against Terrorism (CTPAT) due diligence questionnaire.

Graebel has concluded that, taken together, our policies and procedures provide reasonable, but not absolute, assurance Graebel has reduced the risk that slavery and human trafficking could be found in our business or in our supply chains. Graebel maintains a system to allow anonymous concerns to be reported, as permitted by law, regulation or ordinance.

We encourage persons both within and outside Graebel to submit any concerns about our operations using this reporting mechanism at www.mysafeworkplace.com or 1.800.461.9330. Graebel will protect any person who makes a good faith effort of reporting such conduct that may violate our policies from retaliation or victimisation.

Bill Graebel SGMS, Chief Executive Officer
Graebel Companies Inc.