MODERN SLAVERY STATEMENT

Personal data

BLS International Services Limited is an acknowledged leader in providing Government to Citizen (G-to-C) services, operating with Head Office in Delhi, India. The Regional Offices in Istanbul, Dubai, Moscow, Brampton, and Casablanca manage Europe, the Middle East, Russia, America, and Africa Regions.

Organization structure, business, and supply chain for BLS International Services Limited:

BLS International Services Limited (“BLS” or "BLS International”) is a listed company in the Indian Stock Exchanges i.e. NSE, MSE and BSE. It is amongst the world’s largest specialist service providers for outsourcing visa, passport, attestation, and citizen services to governments and diplomatic missions globally. The company serves Diplomatic Missions, Embassies & Consulates, and Governments in managing all administrative and non-judgmental tasks related to the visa application/citizen services process, enabling them to focus entirely on the critical aspect of assessing the applications.

BLS has operations in 65+ countries, with more than 15,000 employees providing services through 12,000+ centres worldwide. BLS delivers its services by either setting up its own offices or through a partner network. The partner network helps us efficiently deliver services in different countries and maintain a strict governance on compliance with local laws and regulations of that country.

A top-level structure of BLS International Service Limited is as below:

Modern slavery and human trafficking are more prevalent in organizations where there is a high need of unskilled workers or manual workers. By the nature of our work, BLS deploys well educated and high skill workers, who have greater awareness on topics of slavery, forced labour or human trafficking. The nature of our work minimises the risk of any such acts. However, given the serious nature of this issue, BLS has still deployed safeguards to prevent any kind of misconduct in this area.

Policies in relation to slavery and human trafficking:

At BLS International, people are at the core of what we do; hence managing human capital responsibly includes respecting human rights, preventing modern slavery and human trafficking. These are the keys to the long-term business success of BLS International. We have zero tolerance of any kind for modern slavery, including forced labour and child labour. Forced labour, including debt bondage and other forms of modern slavery, is not accepted in any of the BLS International locations.

BLS International recognises that modem slavery is a heinous crime that affects communities and individuals across the globe. BLS International has already undertaken actions to promote ethical business practices and policies that protect workers from being abused and exploited in our organisation. The following safeguards and policies are currently in place:

• BLS International has existing policies and procedures documented in the Code of Conduct ("COC") and Ethics. The code of conduct states that BLS International discourages any kind of modern slavery, employment of children, deploying its employees in conditions that violate their basic rights, and maintaining a zero-tolerance on modern slavery or human trafficking by any of its employees or partners.

• Ensured that our systems contain appropriate processes to protect lesser-skilled workers
  engaged in overseas locations. BLS International does not transfer lower-skilled workers from one country to the other, thus eliminating the risk of human trafficking. Only high skilled workers who have received higher education are deployed in other countries. They are recruited for those roles with a well-documented HR process.

• BLS International works with partners to set up offices in some of the countries. We have defined guidelines that all partners must adhere to. These partners sign a declaration of their commitment to discouraging and not deploying any practices that encourage modern-day slavery or human trafficking.

• BLS International has constituted a Consequence Management Committee (CMC) that works as an Ombudsman to all employees for grievances of serious nature. BLS believes in creating a healthy and nurturing work environment and has empowered all its employees with direct access to the CMC to report any matter that violates our core values, ethical standards, acts of corruption, acts of modern-day slavery, human trafficking, etc.

• BLS International also has a whistleblowing policy, which the employees can use to highlight any irregularity, fraud, misconduct, acts of modern-day slavery, human trafficking, etc.

Due diligence processes in relation to slavery and human trafficking in its business and supply chains:

• In addition to providing services on its own, BLS appoints partners for the delivery of services in some countries. We conduct stringent due diligence for appointing potential partners to provide services. At the time of partner evaluation, background verification is carried out to see if there has been any violation of human rights or if the partner participated in any modern-day slavery practices, human trafficking, or employment of children.

• In countries where BLS hires their own staff, the process of short-list and selection is well documented to eliminate concerns of human trafficking. The job roles and responsibilities have been clearly defined and published to minimise any concerns of modern day slavery practices.

Assess and manage risks for parts of business and supply chain with a risk of slavery and human trafficking:

BLS International is a global organization with offices in many companies. Some of the offices are maintained by partner organizations. BLS has assessed the risk of slavery and human trafficking and manages those through following:

• The nature of work requires a skilled workforce, that has received the benefit of education and can demonstrate a high level of communication skill, personal organization, and technology literacy. The chances of slavery and human trafficking are negligible in occupations where skilled workers are hired.

• While setting up offices in different countries, BLS recruits people through a well-documented process where aspirants have to apply wilfully based on the job description, qualification criteria, and the selection process. This method of a well-documented process and a wilful application keeps practices of slavery and human trafficking at bay.

• BLS International has implemented social listening to monitor our partners for use of modern-day slavery practices and human trafficking.

Effectiveness in ensuring that slavery and human trafficking is not taking place in the business or supply chains:

• BLS continues to follow the strict implementation of its policies of thorough background verification of partners before onboarding them to assist in the delivery of operations in some countries.

• BLS is conducting a review of all the operations for any kind of violation in the area of modern-day slavery and trafficking-related risks. We have prioritized these reviews based on the countries and segments where we have assessed that we may have the highest risks of violation.

Training about slavery and human trafficking available to the staff:

• BLS International conducts awareness training on the Code of Conduct for anyone joining the organization. This is done to emphasise our commitment to fight against modern-day slavery and human trafficking.

• Given our commitment, we conduct mandatory refresher training on the Code of Conduct every year for all employees. We emphasise the importance and discuss case studies and situations that could be considered acts of human rights violation or modern-day slavery practices. These discussions are a proactive way of creating awareness amongst our employees. Once the employees have attended the training, they are required to state their compliance by signing the COC document every year.

• BLS also conducts training on the use of the Consequence Management System to highlight any act of misconduct including modern day slavery and human trafficking.

The statement is made in accordance with Section 54 of the Modern Slavery Act 2015 and has been approved by the Board of BLS International Services (UK) Limited.

Director’s name: Mr. Gaurav Aggarwal