1. Commitment and scope
Registered office (Nevis)
OmertaCall LLC, Hunkins Waterfront Plaza, Suite 556, Main Street, Charlestown, Nevis.
EU establishment (Dublin, Ireland)
OmertaCall (Irish branch of OmertaCall LLC), Office Suites Club, 20 Harcourt St, Saint Kevin's, Dublin 2, D02 H364, Ireland.
OmertaCall LLC rejects slavery, servitude, human trafficking, forced or compulsory labour and child labour. People must be free to choose their employment and leave it in accordance with lawful terms, without coercion, threats or unlawful penalties.
This statement sets the standards for our own business and our relationships with suppliers. It is a voluntary policy statement, rather than a representation that a particular statutory reporting threshold is met. It does not claim that our supply chain has been independently verified as free of exploitation.
2. Organisation and supply chain
OmertaCall provides business telecommunications and related software services. Relevant supply-chain relationships include carriers and number providers, hosting and infrastructure providers, software vendors, and professional or operational service suppliers. Labour risks can arise in their subcontracting arrangements as well as in the direct contractual relationship.
Responsibility for an issue does not disappear because the affected worker is employed by another company. Supplier selection and ongoing reviews must consider the people delivering the service, alongside security, reliability and commercial terms.
3. Policies and expectations
Our policy requires fair recruitment and lawful working conditions. Suppliers must not use forced labour, withhold identity documents to restrict movement, charge workers unlawful recruitment fees, or tolerate threats and coercion. Employment terms must be understandable to the worker, and wages and working hours must comply with applicable law.
Suppliers are expected to communicate these requirements to relevant subcontractors and provide a route for workers to raise concerns without retaliation. Procurement decisions must not reward arrangements that depend on exploitative working conditions. Staff must escalate credible concerns rather than treating contractual assurances as sufficient evidence on their own.
4. Due diligence on suppliers and carriers
Due diligence must be proportionate to the supplier's location, service, workforce and use of subcontractors. Before engagement, the responsible team should identify the contracting entity, understand how the service is delivered, and request relevant labour policies and explanations of recruitment and subcontracting practices where risk warrants them.
Carrier and infrastructure reviews should examine whether critical services depend on opaque chains of subcontractors. Higher-risk suppliers should be asked for supporting evidence and corrective commitments, rather than a statement of compliance alone. Contract terms should require lawful labour practices, cooperation with enquiries and appropriate remedies for breaches.
5. Risk assessment and response
Risk reviews must consider recruitment through intermediaries, migrant or temporary labour, excessive subcontracting, work in locations with weak labour protections, and commercial pressure that could encourage abuse. These factors guide enquiry; they do not establish that exploitation has occurred.
Where a concern is substantiated, the response should prioritise the safety of affected people. Actions may include seeking specialist advice, requiring a time-bound remediation plan, pausing new work or ending the relationship where remediation is refused or ineffective. Abrupt withdrawal must be assessed for the harm it could cause workers. Suspected crimes must be referred to the appropriate authorities where required by law.
6. Training and reporting concerns
People responsible for procurement, supplier management and relevant operational decisions must receive guidance on warning signs and escalation. Refresher guidance should address lessons from supplier reviews and changes in risk. Managers must make clear that raising a concern in good faith must not lead to retaliation.
Workers, suppliers and others can report concerns to [email protected] with the subject “Labour rights concern”. Include the organisation and service involved and a safe way to contact you. Do not send sensitive personal documents in the first email. Information should be shared only with those who need it for assessment, remediation or a legal obligation; absolute confidentiality cannot be promised.
7. Effectiveness and review
Management should assess effectiveness through the coverage and quality of risk-based supplier reviews, completion of relevant training, issues raised, and progress on corrective actions. A lack of reported incidents is not proof that no exploitation exists.
Reviews must consider whether workers can use reporting routes safely and whether remediation addresses underlying causes. This statement does not publish historical completion rates, audit results or numerical targets that have not been verified. The policy and this statement should be reviewed periodically and when material risks change.
8. Governance and approval
Senior management is accountable for this policy; procurement and operational leads are responsible for implementing it in supplier relationships. Material findings must be escalated to senior management with an owner and a proposed response.
Approval line: OmertaCall LLC senior management — formal approval and authorised signatory details are to be recorded before this statement is relied upon as a statutory annual statement. No named director signature, approval date or financial reporting period is asserted here.
9. Contact
For legal matters or a request for further information about this statement, email [email protected] or write to OmertaCall LLC at the Nevis address above. Our Terms of Service and Acceptable Use Policy describe related standards for use of our services.