A human rights and fair work policy, clause by clause

What a human rights policy for a company actually says

A human rights policy is a company's written commitment to how it treats the people it employs, contracts and works alongside: no forced or child labour, freedom to organise, fair treatment regardless of personal characteristics, and a way to report a breach. "Modern slavery policy" and "fair work policy" describe overlapping ground from different angles, forced labour and trafficking risk in one case, day-to-day employment fairness in the other.

This page serves two readers. A procurement or compliance contact assessing Ripe Leads wants to know the commitment is real and stated in specific terms, not marketing language. A small company owner has been asked for a human rights policy, a modern slavery statement, or something like it, by a customer or a tender, and does not know where to start.

Ripe Leads, the trading name of UAB "Kofi Tech", publishes its own version as ŽTP-1, the Human Rights and Fair Work Policy, one of thirteen documents on its sustainability page. It states that its content "follows the core conventions of the International Labour Organization and the UN Guiding Principles on Business and Human Rights".

The law and frameworks behind a human rights policy

Two non-binding frameworks sit behind almost every company human rights policy, including ours. The UN Guiding Principles on Business and Human Rights, endorsed by the UN Human Rights Council in 2011, set out three pillars: the state's duty to protect against human rights abuse by third parties including business, the corporate responsibility to respect human rights by avoiding and addressing adverse impacts, and the need for access to remedy, judicial and non-judicial. The UNGPs create no binding legal obligation by themselves, but they are the reference point instruments such as the EU's due diligence directive explicitly build on.

The International Labour Organization recognises ten fundamental conventions in five categories, updated in 2022 to add a fifth: freedom of association and collective bargaining (C87, C98), elimination of forced or compulsory labour (C29, C105), abolition of child labour (C138, C182), elimination of employment discrimination (C100, C111), and a safe and healthy working environment (C155, C187). A company that states it follows the ILO's core conventions is referencing this specific list, not a general sentiment.

On pay specifically, the EU Pay Transparency Directive, (EU) 2023/970, has a transposition deadline of 7 June 2026. Its Article 5 requires employers to tell job applicants the initial pay or pay range before interview or before a contract is signed, and bars asking a candidate about their current or past pay. That applicant-facing duty does not appear to be limited by company size in the directive's own text, so it likely reaches even a small employer, though this has not been independently confirmed against Lithuania's own transposing legislation. The directive's separate gender pay gap reporting duty is tiered by headcount and does not bind an employer under 100 workers unless a Member State chooses to extend it, which has not yet been confirmed either way for Lithuania.

Lithuania's own Labour Code sets an equal-treatment duty directly at Article 26, requiring every employer to apply equal recruitment criteria, equal working conditions, equal criteria for assessing work and deciding layoffs, and equal pay for equal or equally valuable work, regardless of company size.

On the modern slavery side specifically, the UK's Modern Slavery Act 2015 requires a commercial organisation with GBP 36 million or more in turnover doing business in the UK to publish an annual statement on the steps it takes against slavery and trafficking in its own business and supply chain, a duty that reaches non-UK companies with any UK business presence.

What a fair work and modern slavery policy needs to include

A fair work and human rights policy should state, plainly, what it prohibits: no child labour, a stated minimum age, no forced labour, no deposit or held identity documents as a condition of work, and no recruitment fee charged to the person being hired. Each of those is a specific, checkable commitment, not a general statement of values.

It should say how pay is set, and confirm it never falls below the statutory minimum, and it should state whether people are free to join a union or bargain collectively without consequence for doing so.

It should also say something about how work is organised: whether remote work or flexible hours are used to keep the work open to people in different locations or health circumstances, rather than assuming everyone can be in one office at one time.

Finally, it should link to a reporting channel for a breach, ideally the same one used for other policy breaches, and state whether a report can be made anonymously.

Spotting a real human rights policy versus a stated intention

A human rights policy that only uses general language, "we respect human rights", "we do not tolerate abuse", without naming a minimum age, a payment term, or a reporting channel, is a statement of values rather than an operating document. Look for the specific negative commitments: does it say what the company does not do, no deposit, no held identity documents, no recruitment fee, no monitoring of private communications, rather than only what it aspires to.

Check whether the policy applies only to employees or also to freelance partners and suppliers. A policy that stops at the company's own payroll misses everyone it contracts with instead of employs, which for many small companies is a large share of the people actually doing the work.

Check the reporting route: is it the same channel used for every other complaint, does it allow an anonymous report, and does it name who handles a report if it concerns someone senior rather than a junior member of staff.

ŽTP-1, our own human rights and fair work commitments

ŽTP-1 applies to "the director, employees, freelance partners and suppliers" (clause 1.2). It sets a minimum age of 18 for any employment or service contract, and requires the same of suppliers and partners through our TTP-1 supplier policy (2.1, 2.2). Work is voluntary and either party may end the contract on its own terms (3.1); the policy states plainly that the Company "requires no deposit and does not take or hold original identity documents as a condition of work" (3.2), and "charges candidates no recruitment or cooperation fee" (3.3).

Candidates and partners are judged on competence and delivered work, with protected characteristics carrying no weight in the decision (4.1, 4.2), and remote work and flexible hours are applied deliberately "so that the work stays open to people in different locations and states of health" (4.3). Freedom to join associations or trade unions and bargain collectively is stated explicitly, with no adverse consequence for doing so (5.1, 5.2).

On pay, ŽTP-1 commits that pay is fixed before work starts and is "never below the statutory minimum" (6.1), paid on time, with partner invoices settled within 10 days (6.2), and working time and rest follow the Labour Code and our own DTT-1 internal work rules (6.3). Personal data is processed under our IAP-1 policy (7.1), and the document states outright that "the Company uses no monitoring software that captures screens or keystrokes" (7.2), a specific negative commitment rather than a general privacy statement. Breach reporting runs through our SKT-1 complaints procedure and may be made anonymously (8.1).

Review and reporting under ŽTP-1

The director reviews ŽTP-1 annually and approves any change by order (8.2), the same cycle every one of Kofi Tech's thirteen governance documents runs on. A breach report under 8.1 goes through SKT-1, which sets its own deadlines for acknowledging and deciding a report, so a human rights concern is not left open-ended once it is raised.

ŽTP-1 was approved by director's order effective 22 September 2026 and is published in full at its own anchor on the sustainability page, mirrored at kofitech.eu/tvarumas.

What this policy does not prove

ŽTP-1 is self-authored and approved internally by UAB "Kofi Tech". It has not been audited, certified or verified by any outside body, and Ripe Leads makes no human rights certification, label or score claim about it. From 27 September 2026, the Empowering Consumers Directive, (EU) 2024/825, bans a self-awarded sustainability label outright, one more reason this page carries no badge.

The policy states commitments and prohibitions; it is not itself a record of every hiring decision or every payment made under it, which sit in internal records the policy assumes rather than publishes. A reader should treat this document the way this page recommends reading any human rights policy: as a specific, checkable commitment, weighed against how honestly it states its own limits.