Code of Ethics

PURPOSE OF THIS STATEMENT

The purpose of this statement is to describe HALO’s commitment to comply with, and respect individuals’ rights under, Human Trafficking, Forced Labor and Child Labor laws, and the responsibilities of our employees and partners to ensure that HALO complies with these laws.

CODE OF ETHICS

HALO, its affiliates, and our employees do not:
(i) tolerate, engage in or support Human Trafficking, Forced Labor or Child Labor of any kind through HALO’s activities, including in its supply chain, or
(ii) assist HALO clients or any other party in doing so.

HALO respects its employees’ rights to agree to terms and conditions of employment voluntarily without coercion, and freely terminate their employment with appropriate notice. HALO ensures that its employees are of legal working age for their position and complies with local laws for youth employment or student work, such as internships or apprenticeships.

ADDITIONAL OBLIGATIONS

In some countries, local laws impose additional obligations on HALO regarding compliance with Human Trafficking, Forced Labor and Child Labor laws which may include, among other things, (i) implementing certain measures (e.g., compliance plans, specific clauses in agreements with third parties, annual certifications, etc.) when entering into contracts with or in support of governments; (ii) making disclosures to the government that Human Trafficking, Forced Labor and Child Labor are not occurring at HALO or within HALO’s supply chain; and (iii) reporting activity to the government that is inconsistent with these laws.

Human Trafficking, Forced Labor, and Child Labor is a serious issue in our industry. HALO takes our commitment very seriously to avoid perpetuating this industry concern. HALO Employees are encouraged to be part of our commitment and report any questions or concerns to their supervisors.