Modern Slavery Act Statement 2024
cFIRST LLC (“cFIRST”) makes this voluntary statement against modern slavery and human trafficking pursuant to section 54 of the Modern Slavery Act 2015.
We oppose slavery, forced labor, child labor and human trafficking in all its forms and make this statement to establish the steps we take to ensure there is no slavery or human trafficking in our business operations and our supply chain.
1. About Us
Headquartered in Ohio, cFIRST is a global digital background screening service provider helping enterprises hire talent through its API-enabled mobile-friendly platform. cFIRST was launched with a vision to help organizations eliminate any inaccuracies in their hiring process, creating an indelible candidate experience and productive workplaces around the world.
Built on the three key values of Character, Commitment and Competence we ensure we follow highest standards of business ethics. This commitment includes protecting human rights and acting with honesty and integrity in our activities.
Our supply chain mainly consists of subcontractors, data providers and vendors as well as suppliers of IT and communications equipment and services; property, office cleaning and other facilities management services; office equipment and supplies; and professional services such as auditors, legal and financial service providers, and recruiters.
Built on the three key values of Character, Commitment and Competence we ensure we follow highest standards of business ethics. This commitment includes protecting human rights and acting with honesty and integrity in our activities.
Our supply chain mainly consists of subcontractors, data providers and vendors as well as suppliers of IT and communications equipment and services; property, office cleaning and other facilities management services; office equipment and supplies; and professional services such as auditors, legal and financial service providers, and recruiters.
2. Our Commitment
We work to combat and prevent slavery in our operations and with respect to our vendors and suppliers by exercising due diligence with respect to those we do business with, continuously vetting those we do business with, and requiring our employees to complete training on our Global Code of Conduct and other relevant policies. We expect our employees to report any known or suspected violation of our Global Code of Conduct and our Global Supplier Code of Conduct, including violations related to slavery, forced labor, child labor or human trafficking, or any other form of discrimination.
3. Due Diligence
cFIRST is committed to identify and monitor the risk of slavery and human trafficking in its supply chain. We have established a Global Supplier Code of Conduct under which we conduct due diligence of suppliers and sub-contractors to ensure that they are committed to ethical labor practices and other laws applicable to our operations, such as anti-corruption, global sanctions, anti-bribery, data privacy and information security. Such due diligence is ongoing throughout our relationship with the supplier or sub-contractor to ensure compliance with our position on slavery and human trafficking.
The due diligence process varies based on the type of supplier or subcontractor, the location of the supplier or subcontractor and other relevant factors but our diligence process may include the evaluation of: legitimacy and structure of their organization; identifying business locations, practices, and operations; screening for legal and financial red flags, sanctions, litigation, regulatory violations, and ongoing investigations; analysis of their policies and compliance programs; and gathering references from other companies using the supplier or subcontractor.
Likewise, we credential our clients to ensure they are legitimate, active, and registered legal entities that are subject to compliance with relevant laws and regulations prior to entering a business relationship with them. All clients must further attest to compliance with all applicable laws and acknowledge that our services will only be used for declared legally permissible purposes.
The due diligence process varies based on the type of supplier or subcontractor, the location of the supplier or subcontractor and other relevant factors but our diligence process may include the evaluation of: legitimacy and structure of their organization; identifying business locations, practices, and operations; screening for legal and financial red flags, sanctions, litigation, regulatory violations, and ongoing investigations; analysis of their policies and compliance programs; and gathering references from other companies using the supplier or subcontractor.
Likewise, we credential our clients to ensure they are legitimate, active, and registered legal entities that are subject to compliance with relevant laws and regulations prior to entering a business relationship with them. All clients must further attest to compliance with all applicable laws and acknowledge that our services will only be used for declared legally permissible purposes.
4. Training
cFIRST requires certain members of our leadership team and Team Members responsible for recruiting/sourcing and managing our supply chain to complete annual training on modern slavery as a module within our compliance training program.
5. Assessment and Ongoing Commitment
Our efforts to ensure that we are not enabling, contributing, or are otherwise linked to slavery or human trafficking are continually refined to minimizing our potential exposure, by controlling evolving risks through strict adherence and routine updating of our policies and due diligence practices. As new trends and risks emerge, we remain committed to complying with the Modern Slavery Act, cooperating with the combatting of forced labor and human trafficking, and holding ourselves and those with which we do business accountable to do the same.
