Modern Slavery and Human Trafficking Statement

Last reviewed and updated: June, 2023

Introduction

At Turium, we’re challenging today to reinvent tomorrow by solving the world’s most critical problems for resilient environments, mission-critical outcomes, and operational advancement, turning abstract ideas into realities that transform the world for good. At Turium, we do things right. We always act with integrity – taking responsibility for our work, caring for our people and staying focused on safety and sustainability. In alignment with our values, we are committed to respecting the human rights and dignity of individuals within our operations, supply chain and communities where we do business.

At Turium, we wholeheartedly support the Modern Slavery Act 2015 (UK) and the Modern Slavery Act 2018 (Cth) (Aust) whose provisions assist to eradicate modern slavery, wherever it may occur, and raise public awareness of the problem. In addition to working to prevent modern slavery in our own supply chains, Turium members are also working with partners to support a wide range of initiatives to eradicate all forms of modern slavery around the world.

We are committed to achieving the highest standards of ethical behaviour in the conduct of our business and activities worldwide. We support and respect the protection of internationally proclaimed human rights and endeavour to make sure that Turium is not complicit in human rights abuses. To this end, we will not tolerate slavery or human trafficking or abusive or unfair treatment in any part of our own business or in any of our supply chains. We are generally, and in particular through our policies and practices in relation to procurement, people and culture and corporate responsibility, committed to taking steps to ensure that slavery and human trafficking play no part in our own business or in our supply chains.

Risks of modern slavery in our operations and supply chains

Given that Turium primarily provides software solutions and professional services to clients, combined with the nature and type of those services, we believe there is low risk of human rights violations and modern slavery in their respective operations and supply chains. Turium is committed to continually improving its approach to identifying modern slavery risks in its supply chains and operations around the globe, including further engagement of third parties to conduct risk assessments and provide expertise on enhancing our approach. We have a zero tolerance approach to modern slavery and all forms of discriminatory or exploitative behaviour and treatment, whether within our own business or that of those who supply us; this stance is made clear in all our policies and behaviours.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business. At Palantir, personnel are required to comply with our code of conduct which sets out our commitment to ethical business practices and regulatory compliance.

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 Palantir 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.

In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free we have reviewed our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues. Our workplace policies and procedures demonstrate our commitment to act ethically and with integrity in all our business relationships and to implement and enforce effective systems and controls to ensure our supply chains are entirely free from slavery and human trafficking.

Due diligence

We conduct due diligence to avoid complicity in human rights abuses, and we seek to avoid causing or contributing to adverse human rights impacts through our own activities and business relationships. Enhanced assessment occurs for suppliers based on risk triggers, which can include geography, activity type and other risk factors.

Contracting and certification

Our standard contracts stipulate that suppliers will comply with all applicable laws, rules and regulations including those related to human trafficking, worker welfare and modern slavery. We also require that suppliers certify compliance with our Supplier Code of Conduct, including its human rights provisions.

Auditing and assessment

As outlined in our Supplier Code of Conduct, we reserve the right to conduct audits and thoroughly investigate possible non-compliance with our requirements. We strive to be prompt and fair in our investigations and, whenever possible, operate in a spirit of continuous improvement – working with suppliers to implement change within specified timeframes. Any violations of our Supplier Code of Conduct or failure to cooperate in an audit or investigation may jeopardise suppliers’ business relationship with us, up to and including termination of contracts.

Training

Turium’ annual Code of Conduct training is required of all employees. It includes information on our commitment to respecting human rights and dignity in accordance with the U.K., Australian Modern Slavery Acts and the United Nations Guiding Principles on Business & Human Rights, as well as our expectations of employees to act in a manner consistent with our Human Rights Policy. Our training for supply management professionals includes a section on our Supplier Code of Conduct, which includes human rights requirements. Additional modern slavery training is under review and being developed for deployment.

Engagement

Turium recognises the importance of stakeholder engagement to create a more connected, sustainable world. We engage with third-party experts and engage in cross-industry collaboration to collectively advance our sustainability strategies and impacts, including human rights. We also seek to assist our clients in these areas, including by sharing strategies and control measures to reduce human rights and modern slavery risks within their operations and supply chains.

Our approach to assessing effectiveness

Key performance indicators: We are committed to continual improvement in managing human rights and modern slavery risk in Turium’s supply chain. To evaluate our performance, we consider both qualitative and quantitative indicators, including but not limited to those related to supplier qualification and certification, audits and assessments, training, client engagement, and external benchmarking.

Reporting: We encourage our employees, suppliers and stakeholders to speak up, without retribution, about any concerns regarding human rights and modern slavery in our operations or supply chain. We are committed to investigating reports in an appropriately robust and timely manner.

Our consultation process: We have ensured that relevant areas of Turium’s operations are aware of what actions need to be taken to identify, assess, and address modern slavery risks in our operations and supply chains.

Signed by the Global Chair and the Global CEO of Turium, being designated and responsible members and directors of each respective entity on their behalf.