Additional Policies

Modern Slavery and Human Trafficking Policy

Cordillera Applications Group (Cordillera) is a research and operations firm dedicated to de-risking client investments and projects through risk analysis, monitoring, and specialized field teams. Cordillera maintains offices in North America and Europe, analysts covering Africa, the Asia-Pacific and the Middle East, local networks, and a proprietary information platform. It undertakes work for a range of governmental, intergovernmental, and private sector clients.

Our Stance.
Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every organisation is at risk of being involved in this crime through its own operations and its supply chain. Cordillera is vehemently opposed to all human rights violations, including the use of slavery in all forms; cruel, inhuman, or degrading punishments; and any attempt to control or reduce freedom of thought, conscience, and religion. Cordillera has a zero-tolerance approach to modern slavery and is fully committed to preventing slavery and human trafficking in our operations and supply chain. We are committed to preventing and tackling all such activities as modern slavery and human trafficking as outlined here.


Our Suppliers & Partners.
We haven’t been made aware of any allegations of human trafficking/slavery activities against any of our suppliers or partners, but if we were, then we would act immediately against the supplier or partner and report it to the relevant authorities. Cordillera expects all of its suppliers and partners to work towards and uphold similar legal, ethical and moral standards in relation to human trafficking/slavery. Cordillera reserves the right to withdraw from any agreement or other arrangement with any supplier or partner who/which is found to have acted in contravention of the spirit or principles of this Policy.


Cordillera takes several measures to identify and prevent slavery and human trafficking in our operations as outlined in our Whistleblowing Policy, due diligence on all new suppliers and partners during on-boarding and thereafter at regular intervals, raising staff awareness of modern slavery issues by incorporating this statement and related policies within our Company Handbook and where necessary undertake training of staff.


Business Ethics and Compliance Policy

Cordillera is committed to the highest standards and practices of responsible business behaviour. Through our working practices we seek to protect and promote the human rights and basic freedoms of all of our staff and those partnering with us or supporting our activities in any way (e.g., our clients and suppliers), whether based in the UK, US or overseas. This policy is non-exhaustive, and all aspects of the Company’s business should be considered in the spirit of this policy.

We are also committed to being a highly ethical Company in all of our internal and external conduct. The highest standard of integrity, honesty, trust, goodwill, and accountability is of the utmost importance to who we are and what we do. As such we will comply with all applicable laws and regulations and expect our staff to do likewise, conducting business in accordance with the letter, spirit, and intent of all relevant laws and to refrain from any illegal, dishonest, or unethical conduct. Business ethics and compliance is the responsibility of all Cordillera staff and will be enforced at all organisational levels. For ease, the term ‘staff’ is used here to mean employees, officers, consultants, contractors, volunteers, interns, casual workers, and agency workers.


Human Rights

Cordillera’s human rights policy is outlined in the company handbook. Cordillera is vehemently opposed to all human rights violations. We ensure that all workers are entitled to their human rights as set out in the Universal Declaration of Human Rights 1948 and international human rights law treaties. Cordillera will not enter into any business arrangement with any person who, or organisation which, fails to uphold the human rights of its staff or who/which breaches the human rights of those affected by the organisation’s activities. We establish a relationship of trust and integrity with all our clients, customers, suppliers and partners, which is built upon mutually beneficial factors.  Our supplier and partner selection and on-boarding procedure includes due diligence of their reputation, respect for the law, compliance with health, safety and environmental standards, references, as well as any other information considered relevant to ethical conduct issues (as appropriate). Cordillera expects all suppliers and partners to work towards and uphold similar ethical and moral standards and reserves the right to withdraw from any agreement or other arrangement with any supplier or partner who/which is found to have acted in contravention of the spirit or principles of this Policy.


Anti-Corruption & Bribery Policy

Cordillera’s policy is to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by US and UK laws, including the Bribery Act 2010, in respect of our conduct both at home and abroad. Our policy is explained in more detail in the company handbook. Our policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located. The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

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