Effective date: January, 1st, 2020
Last reviewed: January, 1st, 2026

Organization: Source Code Staffing Inc. (“Source Code,” “we,” “us”)

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1) Purpose

Source Code is committed to preventing modern slavery, forced labour, child labour, and human trafficking in our operations and supply chain. This policy outlines the minimum standards we follow and the practical controls we maintain.

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2) Scope

This policy applies to:

• Source Code Staffing Inc. employees, contractors, and representatives

• All suppliers, subcontractors, and service providers (“third parties”) that support our business

• Our staffing, recruiting, payroll/finance, and related workforce services

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3) Our Business

Source Code is a staffing and workforce solutions firm headquartered in Canada. We support clients primarily in Canada, the United States, and the European Union. We may engage third parties for services such as information technology consulting, payroll administration, background screening, IT, and recruiting support.

 

4) Our Commitment & Prohibited Practices

We do not tolerate any form of:

• Forced labour, prison labour (where prohibited), bonded labour, or involuntary labour

• Human trafficking or exploitation

• Child labour that violates applicable laws

• Withholding identity documents, coercion, threats, or restriction of movement

• Charging candidates unlawful recruitment fees or requiring deposits in exchange for work

 

5) How We Manage Risk (Our Controls)

To keep this practical and enforceable, we maintain the following baseline controls:

A. Candidate & Worker Protections

• We do not charge candidates recruitment fees for placement.

• We require written agreements for placements or engagements (as applicable).

• We support worker concerns being raised without retaliation.

B. Third-Party / Supplier Expectations
We expect third parties supporting Source Code to:

• Comply with applicable labour and employment laws

• Prohibit forced labour and human trafficking in their operations

• Allow Source Code to end the relationship for serious non-compliance

C. Due Diligence (Reasonable Checks)
We take a risk-based approach. Depending on the relationship, we may:

• Review the third party’s website/policies and business information

• Confirm the services location(s) and whether subcontracting is used

• Require contractual acknowledgements of this policy

• Use screening tools/assessments for higher-risk relationships when appropriate

D. Contracts & Termination
Where practical, our contracts include language that:

• Prohibits forced labour/human trafficking

• Requires legal compliance and cooperation with investigations

• Allows termination for cause if serious violations are identified
   

6) Reporting Concerns (Speak Up)

Anyone can report suspected modern slavery, forced labour, or human trafficking concerns related to our business.

Report by email: [Shruti.Thakur@sourcecodestaffing.com]
Subject line: “Modern Slavery / Forced Labour Concern”

Reports may be made confidentially. We do not tolerate retaliation against anyone who raises a concern in good faith.
 

7) Investigation & Remediation

If we learn of a credible concern, we will:

• Review the information promptly

• Engage relevant parties and request documentation where appropriate

• Take reasonable action based on severity, which may include corrective actions, suspending work, reporting to appropriate authorities (where required), and/or terminating the relationship
   

8) Training & Awareness

We provide basic awareness to staff involved in recruiting, vendor selection, and onboarding so they can identify common red flags (e.g., coercion, recruitment fee concerns, document withholding, unexplained subcontracting).

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9) Governance & Review

Policy owner:  Compliance and Security Officer, Shruti Thakur

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This policy is reviewed at least annually and updated as needed.

Approval:
Name: Shruti Thakur
Title: Compliance and Security Officer
Date: January, 1st, 2026