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Modern Slavery Act Statement


ATOTO recognizes the Modern Slavery Act 2015 of UK (the "Act") and has zero tolerance of slavery servitude, and forced or compulsory labor, child labor and human trafficking both in our own business and in our supply chain. We are committed to taking all necessary steps to ensure the compliance with the Act and to minimize the risk of working with any organization that engages in such practices.

Organization Structure and Supply Chain

Our business is to produce, to sell and to market OEM and universal android car multimedia, android DVD headrests, amplifiers, speakers etc.. Our supply chain is in mainland China and focused on electronics manufacturing services, as such it has been identified as an area of risk.

Modern Slavery Act Working Group and Initiatives

In November 2015, ATOTO established our own Modern Slavery Act working group consisting of the representatives of Legal & Compliance, Human Resources; Supply Chain and Corporate Finance. The working group's responsibilities include:

  • Updating the relevant policies of ATOTO to make sure they comply with the Act.
  • Accessing and identifying risks, within ATOTO group and ATOTO's supply chain, of non-compliance with the Act, and the follow-up actions or steps to be taken by ATOTO to combat the non-compliance of the Act.
  • Receiving information related to the Act.
  • Delivering training to staff.
  • Ensuring the message of anti-slavery be delivered to the suppliers.
  • Arranging for the preparation and publication of the annual statement within the six months after the financial year end.
  • Conducting anti-slavery investigations and due diligence within ATOTO group on yearly basis.

Relevant Policies

ATOTO has been in the process to amend its Employee Code of Conduct and the following statement will be added to it: "ATOTO has zero tolerance of slavery servitude, and forced or compulsory labour, child labor and human trafficking both in our business. " The Code of Conduct encourages ATOTO's employees to report any concerns related to the activities of ATOTO or its supply chains. To make it easy for ATOTO employees to make disclosures, we encourage them to use the email of the Human Resources Department for confidential disclosure and reporting.

ATOTO has been in the process to update its procurement policies in order to ensure that its suppliers treat workers with dignity and respect, and provide safe working conditions where necessary. Serious violations of the ATOTO's procurement policies will lead to the termination of the business relationship.

Due diligence

ATOTO undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. ATOTO has been working on its suppliers due diligence process which will include:

  • conducting supplier audits or assessments through ATOTO's own staff or third party auditor, which have a greater degree of focus on slavery and human trafficking where general risks are identified; and
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our procurement policies, including the termination of the business relationship.

Performance indicators

ATOTO has reviewed its key performance indicators (KPls). As a result, the organization is:

  • requiring all staff to have completed training on ethics, which modern slavery is part of. In this training, we encourage all employees to use the whistle-blower hotline to report all concerns regarding the workplace and supply chains.
  • reviewing and evaluating the current suppliers via due diligence questionnaires to ensure the compliance with the Act.

Single Director's signature: