Anti-slavery policy

INTRODUCTION

This policy sets out the position of the SSQ Group on opposing modern slavery and human trafficking as part of SSQ’s business and supply chain.

1. OUR ANTI-SLAVERY POLICY STATEMENT

1.1 Modern slavery is a crime and a violation of fundamental human rights. It can take numerous forms, such as slavery, servitude, compulsory and/or forced labour and human trafficking, all of which represent the deprivation and manipulation of a person’s liberty by another to exploit them for personal or commercial gain. SSQ is committed to a zero tolerance approach to modern slavery, to acting ethically and with integrity in its business dealings, and to implementing systems and controls to ensure a modern slavery is not taking place in our own business or in our supply chains.

1.2 SSQ is committed to exhibiting transparency in our approach to tackling modern slavery throughout our supply chains, consistent with applicable legal obligations. We expect the same standards from our business partners, suppliers and contractors, will not contract with any organisation or person who we suspect may be engaging in the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude.

2. COMPLIANCE WITH THIS POLICY

2.1 This policy applies to all persons working for us, with us, or on our behalf in any capacity, including all employees, directors, officers, volunteers, agency workers, agents, contractors, consultants, business partners and third-party representatives.

3. RESPONSIBILITY FOR THIS POLICY

3.1 SSQ’s legal team has overall responsibility for this policy and can be reached at [email protected].

3.2 SSQ’s Operations Team has primary responsibility for implementing this policy, monitoring its use, dealing with queries, and reviewing internal controls and procedures to ensure they are effective.

3.3 Management at all levels are responsible for ensuring that their managees understand and comply with this policy.

3.4 This policy does not form part of an employee’s contract of employment, and SSQ may amend it at any time.

4. YOUR OBLIGATIONS UNDER THIS POLICY

4.1 You must ensure that you read, understand and comply with this policy.

4.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of those working for us or under our control. You are required to avoid any activity that might lead to, suggest, or have as a possible future consequence a breach of this policy.

5. NOTIFICATION IN CASE OF NON-COMPLIANCE

5.1 You must notify SSQ’s Operations Team as soon as possible if you suspect or believe that a breach of this policy has occurred or may occur.

5.2 You are encouraged to raise concerns about any suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage. SSQ will support anyone who raises a concern in good faith, even if it is mistaken.

5.3 If you are unsure about whether a particular act, the general treatment of workers, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with the Operations Team.

6. BREACHES OF THIS POLICY

6.1 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.