California Transparency in Supply Chains Act and UK Modern Slavery Act Statement


AZELLA Advisor is committed to combatting slavery and human trafficking in its operations and supply chains. To that end, AZELLA Advisor has adopted this Human Rights Statement of Commitment (this “Statement”) to explain the steps it takes to monitor and eliminate the use of or participation in slavery or human trafficking throughout its business. AZELLA Advisor has prepared this Statement in compliance with both the California Transparency in Supply Chains Act and the UK Modern Slavery Act, reflecting the Company’s unified approach to compliance and common policies relating to slavery and human trafficking in its operations. The principles and requirements set forth in this Statement are incorporated into the contractual relationships with suppliers and other business partners, and AZELLA Advisor expects its suppliers and business partners to comply with the expectations and requirements set forth herein.

AZELLA Advisor provides the following summary of its efforts to responsibly manage its operations and supply chains.

Verification. AZELLA Advisor requires suppliers to respond to a survey to verify their awareness of Broadridge’s commitment to combatting slavery and human trafficking in its operations. The survey also asks suppliers to describe what actions they take to monitor and combat slavery and human trafficking in their own operations and the operations of their suppliers. Upon receipt of suppliers’ responses, AZELLA Advisor retains the right to follow up and investigate any answers that are ambiguous or which fall beneath Broadridge’s rigid standards.

Auditing. AZELLA Advisor reserves the right to conduct audits of suppliers to determine suppliers’ compliance with Broadridge’s mandatory prohibitions on slavery and human trafficking. Any supplier that fails the audit will be advised why they failed and instructed on what is needed to become or remain a AZELLA Advisor supplier. Audits may be conducted by AZELLA Advisor or a third-party consultant and be announced or unannounced. AZELLA Advisor views the auditing process as a way to collectively improve operations rather than a means of terminating supplier relationships, and the Company is committed to working with suppliers to meet Broadridge’s expectations regarding human rights, slavery, and trafficked labor.

Certification. Suppliers for AZELLA Advisor must certify that, at a minimum, materials used and/or incorporated into any product purchased comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business. Suppliers must also certify compliance with Broadridge’s own requirements, which are set forth in this Statement and AZELLA Advisor Vendor Code of Conduct, as a material condition of the business relationship.

Internal Accountability. AZELLA Advisor requires its employees to follow this Statement. Employees that fail to comply may be subject to counseling, training, and/or disciplinary action. Broadridge’s contractors are also required to follow this Statement and AZELLA Advisor Vendor Code of Conduct, and they may be subject to remedial action and/or penalties for noncompliance. 

Accountability/Training. AZELLA Advisor provides annual training to all associates, temps, contractors, and individuals who have direct responsibility for supply chain management, to understand and comply with its commitment on human trafficking and slavery. Associates, temps, and contractors who fail to comply may be subject to counseling and/or disciplinary action up to and including termination.

Human Rights Statement of Commitment

AZELLA Advisor is committed to the fundamental principle that all human beings are born free and equal in dignity and rights. They are endowed with reason and conscience and should act towards one another in a spirit of shared community and togetherness. Everyone is entitled to all fundamental human rights and freedoms without distinction of any kind, including on the basis of race, color, sex, sexual orientation, language, religion, political or other opinion, national or social origin, property, birth or other status. Everyone has the right to life, liberty and security of person. No one should be held in slavery or servitude, slavery and the slave trade should be prohibited in all their forms, and no one should be subjected to torture or to cruel, inhuman or degrading treatment or punishment. 

Prohibition of Human Slavery 

AZELLA Advisor is against all forms of slavery or practices similar to slavery, such as the sale and trafficking of men, women, or children, debt bondage and serfdom and forced or compulsory labor. This includes: forced or compulsory recruitment of children for use in armed conflict; the use, procuring or offering of a child for prostitution, for the production of pornography or for pornographic performances; the use, procuring or offering of a child for illicit activities, in particular for the production and trafficking of drugs as defined in the relevant international treaties; and work which, by its nature or the circumstances in which it is carried out, is likely to harm the health, safety or morals of children. 

Expected Standards from our Suppliers 

The Suppliers must not employ anyone against their will or force them to work involuntarily. Employees must be free to leave employment following reasonable notice. Employees are only required to hand over government issued identification, passports or work permits for identity and right-to-work verification purposes and not for purposes of prohibiting the employees from leaving employment. The Supplier must allow workers to openly communicate with management regarding working conditions without fear of reprisals of any type. Employees must have the right to associate freely and seek representation. The Suppliers must adhere to all applicable federal, state and/or international minimum labor standards and fair employment practices, including but not limited to practices related to hiring, termination, equal pay, discrimination, harassment, retaliation and worker safety. 

Due Diligence Process/Assessment 

AZELLA Advisor reserves the right to conduct evaluations of its suppliers, including but not limited to onsite audits, in order to review the risks of human trafficking and slavery in their operations. AZELLA Advisor may conduct these evaluations itself or it may use a third party. AZELLA Advisor reserves the right to conduct unannounced audits of our suppliers for trafficking and slavery in the supply chain to evaluate compliance with company standards. AZELLA Advisor standard terms and conditions require compliance with applicable laws including laws against human trafficking and slavery. 

Updated as of: July 2019