January 2021

Targa Telematics S.p.A. trading as Targa Telematics UK
Modern Slavery and Human Trafficking Statement

Introduction

This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 2020.

The statement sets down Targa Telematics’ commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small.  Staff are expected to report their concerns and management to act upon them, since we adopt a zero-tolerance approach to slavery and human trafficking.

Organisational structure and supply chains

Targa Telematics is a leading provider of digital platforms, mobility solutions and applications for short and long-term renters, financing companies and large fleets, with services ranging from insurance telematics to fleet management, diagnostics and remote telemetry of private, professional and construction vehicles, through to the management of airport vehicles.

We operate in the IoT industry offering innovative smart mobility solutions for the benefit of people, businesses and the environment.

Targa’s supply chain in this context consists of many organisations made up of hardware/electronic manufacturers and connectivity suppliers, web-based services, logistic fulfilment centres responsible for the distribution of our products, procurement vendors and recruitment and employment agencies from whom Targa employees may be sourced.

Although our Company directly provides and licences IoT software mobility solutions we are currently sourcing a part of our hardware solutions from our partners, that may also be located overseas.

The Company currently operates directly in the following countries:

  • With its main location offices in Italy (Treviso and Turin operational branch), Targa Telematics operates in all the European Countries principally also through its offices in France (Paris) and UK (London). To see more please visit https://www.targatelematics.com/en/contacts/

Potential Risk Activities

Our Company operates mainly through the provision of SaaS solutions enabled by sourcing hardware from third parties. Although respect of the fundamental human rights is ultimately our suppliers’ responsibility, Targa could be exposed to the risk of indirect modern slavery liabilities through the products it imports. We are aware of this risk and put in place some countermeasures to avoid any form of Modern Slavery, applicable for all our employees and effective for whoever cooperates with us. Our standard suppliers’ contract and grant agreement templates have been updated to include human trafficking warranties and undertakings. We expect our supply chain to respect and comply with all applicable laws, including the Modern Slavery Act 2015, and we reserve the right to terminate our commercial partnership or contractual obligations with any supplier who is found to be in breach of, or who fails to comply with the Act. This applies to any supplier in any type of contractual agreement with us both domestically and internationally.

Responsibility for the Company’s anti-slavery internal initiatives is as follows:

1.1Policies: H.R: Manager is responsible for creating and reviewing policies. We apply the highest possible standards in the recruitment and employment of our people. All of our permanent employees are employed and paid (as a minimum the living wage) directly by Targa Telematics and not via third party. The process by which policies are developed is based on best industry practices. E.g. we have in place: an inclusion policy to give the opportunity to all types of people of being included in the recruitment process, with particular attention being given to candidates with disabilities. Our exit interview policy includes a check to determine if the reason of leaving is due to an uncompliant behaviour, harassment or any situation that could damage the brand of the company.

1.2Risk assessments: the Health and safety Manager is responsible for risk assessments by a process strictly bounded within our HR policies, which includes periodical online training courses to be attended by every single employee. By the end of the course, which consists of 8 hours training, employees must compulsorily correctly pass at least 75% of questions, the tests at the end of each section and of each module. The certification is valid for 5 years.

1.3Due diligence: our CFO is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking. As part of a new initiative to mitigate the risks, in 2020 we initiated a program of due diligence that we conduct on direct suppliers who could have a higher than average slavery and human trafficking risk. We regularly inspect our high-risked suppliers’ facilities to ensure quality output of the products and the process they are made with, also through recognised quality certifications including ISO/TS 16949. It is our intention that our due diligence process should continue in perpetuity and be periodically updated.

Policies - context and details

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.

Our Company takes pride in complete transparency and shares its fundamental values by a dedicated presentation for every employee commencing from  the first days of their onboarding activity.

These values can be summarised as follows;

  • Honesty;
  • Passion;
  • Altruism and Trust;
  • Courage;
  • Communication;

Moreover, Targa supports and is committed to upholding the UN Guiding Principles on Business and Human Rights and the core labour standards set out by the International Labour Organisation.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations

2.1 Whistleblowing policy – the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains, and encourages any member of staff to report any known or suspected breach of our ethical standards including slavery, human trafficking, forced or child labour, as well as wider human rights-related issues in accordance with the procedure set out in the policy. It guarantees that any issue can be raised in confidence and refers to examples of forced, compulsory or trafficked labour as instances which we expect to be reported. These practices are protected by Targa’s employment contract of any employee.

2.2Employee code – Our steps to implement our general Supplier Code of Conduct are ongoing. Meanwhile the conditions contained in each employment contract sets down the actions and behaviour expected of employees when representing the Company. In fact, our employees covenant with us (on our Company behalf and as trustee and agent for each Group Company) that they shall operate in accordance with our Policy principles reported above.

2.3Corporate Social Responsibility (CSR) Policy – The Company’s CSR policy summarises our commitment to respect human rights and acting in a socially responsible manner in our operations and programming, our diversity inclusion and our promotion for a safe and healthy environment and work spaces. For example, Targa co-creates with its customers new sustainable mobility models to reduce CO2 emissions, decrease traffic congestion and shape an environmentally sustainable mobility future for all, aiming to contribute positively to the community, supporting various cultural activities and provides some scholarships, funding and promoting organisations for young patients affected by health problems and their families (“La Città della Speranza”).

Training

Regular refreshment of the complementary material given to employees is ongoing. Feedback is encouraged to develop improvement of Policy and future updates of the training material for all Targa employees. 

Due Diligence Processes for Slavery and Human Trafficking

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear that we will apply a zero-tolerance-policy against human trafficking and slavery, evaluating the modern slavery and human trafficking risks of each new supplier and invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

Performance indicators

The Company uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains, including use of labour monitoring and payroll systems.

  • We make sure that all of our Suppliers business relationships relies explicitly on ethical conducts and values, prohibiting Suppliers and their employees and sub-suppliers from engaging in modern slavery and generally commit not to transgress local, international laws and also relevant recommendations;
  • In cases of high-risk, we may also audit the Supplier and, as appropriate, we require him to take specific measures to ensure that the risk of modern slavery is significantly reduced;
  • progress on implementation of our quality policy and third parties vendor policy into our supplier management systems and processes: all our suppliers have been asked to provide ISO 9001 certification to evidence action they have undertaken as a first step in this matter.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. Targa’s Board endorses this policy statement and is fully committed to its implementation.

This Modern Slavery and Human Trafficking Statement has been approved and authorised by:

 

Name:

Nicola De Mattia

 

Position:

CEO

Date:

Reviewed on 2021, Jan. the 7th