Modern Slavery and
Human Trafficking Statement
Introduction from the Chief Executive Officer, Jack Harrington
Research Innovations Incorporated (“RII”) ensures that we trade ethically, source responsibly, and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain. This statement highlights the key activities we have undertaken during this financial year to combat modern slavery in our organisation and supply chain.
Organisational structure and business
We are a global provider of software solutions and engineering services for defence and security supporting a large customer base. We focus on performing cutting-edge research and development of information systems that support Joint Command and Control, Mobile Computing, and Cyberspace. We operate mainly in the United States, Canada, and Europe, with headquarters in Northern Virginia.
Our Supply Chain
Our supply chain consists mainly of professional and office services and office goods. Professional service suppliers include providers of data licenses, consultants in various fields, travel agents, and outside legal counsel. Office services suppliers include, for example, delivery services, catering, maintenance, repair, and cleaning services. Office goods suppliers include, for example, computer hardware and software, copiers, telephone, office furniture and fixtures, office supplies, and related goods.
Our Policies on Slavery and Human Trafficking
RII has a zero-tolerance policy for slavery and human trafficking. We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all of our policies.
Our Employee Handbook reflects our commitment to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.
RII’s Employee Handbook expressly prohibits employees from: (a) engaging in any forms of trafficking of persons; (b) procuring commercial sex acts; (c) using forced labor; or (d) engaging in any other activities deemed unlawful by the Victims of Trafficking and Violence Prevention Act (TVPA). Employees who are believed to have participated in human trafficking activity of any kind are referred to the appropriate authorities for possible criminal prosecution. RII employees are advised to report trafficking concerns to RII’s Chief Ethics Officer, to the Global Human Trafficking Hotline at 1-844-888-FREE, or by emailing concerns to firstname.lastname@example.org.
RII has the following policies in place relevant to modern slavery, which we continuously review and update:
A code of ethics detailed in our Employee Handbook and a designated Chief Ethics Officer;
A vetting process for all business partners; and
Annual certification in the USG System Access Management database (SAM.gov) to its compliance with US anti-trafficking of persons regulations (Federal Acquisition Regulation Part 52.222-50 Combating Trafficking in Persons).
Due diligence processes for slavery and human trafficking
We believe the risks of slavery and human trafficking practices directly within our business are very low. Our business is sophisticated software development that does not involve the type of labor often associated with such practices. Our office services suppliers are engaged in a range of activities, from higher skilled to lower skilled, but almost all are engaged in services conducted in close proximity to or in close cooperation with RII personnel. Consequently, these services are conducted in a professional environment where exploitive practices would be difficult, if not impossible, to hide. Our suppliers of office goods are reputable retailers and wholesalers. We do not contract with source suppliers based in industries or regions of the world where the risks of modern slavery and human trafficking are relatively high.
As part of our initiative to identify and mitigate risk we have in place processes to:
Identify and assess potential risk areas in our supply chains by conducting a due diligence review on all of our supply chain partners via SAM and Office of Foreign Assets Control (OFAC) reviews; by conducting these reviews and verifying or eliminating current or potential supply chain partners on a pass/fail basis allows us to:
Mitigate the risk of slavery and human trafficking occurring in our supply chains; and
Monitor potential risk areas in our supply chains;
Protect whistleblowers. We encourage anyone who suspects modern slavery or human trafficking to report it immediately either to our Chief Ethics Officer or to an established whistleblowing hotline.
Supplier adherence to our values
To ensure all those in our supply chain and contractors comply with our values, we are adding supply-chain specific elements to our compliance program. At a minimum, RII will include the flow-down of our Government customer standard contract clauses in our subcontract agreements. RII currently holds Direct Commercial Sale contracts in the United States and in the United Kingdom. As such, these clauses will include FAR 52.222-50 Combating Trafficking in Persons and Modern Slavery Act of 2015 adherence, respectively.
We have a dedicated Chief Ethics officer who reports directly to our Chief Executive Officer, who works with our Legal, Procurement, and HR teams on issues relating to slavery and human trafficking.All RII consultants are included in our annual ethics training, which includes matters relative to modern slavery and human trafficking.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide annual ethics training to our staff. Further, we require our supply chain to provide RII with an annual certification confirming compliance with anti-modern slavery and human trafficking regulations and laws within their companies.
Our effectiveness in combating slavery and human trafficking
Each year, 100% of RII’s population and all consultants receive annual ethics training, to include awareness of RII’s zero tolerance policy of slavery and human trafficking as well as avenues for reporting any concerns. To date, RII has received no reported breaches.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2022. It was approved by the board on 8 May 2023.
Jack G. Harrington
Chief Executive Officer
Research Innovations Incorporated
Last reviewed and updated: 8 May 2023