Modern Slavery Act

SBS INSURANCE SERVICES MODERN SLAVERY ACT

Statement of Intent

This Document aims to set out SBS’s understanding of and commitment to the Modern Slavery Act 2015

Policy

SBS has implemented an Anti-slavery and anti-trafficking policy reflecting its commitment to combatting slavery and human trafficking and to acting with integrity in all its dealings, relationships, and supply chains. The policy outlines how our various procurement and HR practices, policies and procedures ensure compliance with its policy commitment.

Anti-slavery and anti-trafficking policy

Modern slavery encompasses slavery, forced and compulsory labour, and human trafficking whereby individuals are deprived of their freedom and are exploited for commercial or personal gain as enacted in the Modern Slavery Act 2015. SBS is committed to combatting slavery and human trafficking and to acting with integrity in all its dealings, relationships, and supply chains. It expects the same high standards from all its staff, suppliers, contractors, and those with whom it does business. This policy applies to all employees, workers, consultants, and other persons doing business with SBS including all its wholly owned companies, contractors, and suppliers.

We acknowledges the risk that a supply chain may involve the use of a hidden or unknown subcontractor reliant on forced labour. Although we consider the risk of modern slavery to be low due to the nature of our supply chains, we consider all elements. Some commodities having a higher risk than others, for example Diamonds and precious stones carries a higher risk than say flooring. The precious stones and metals Supply chain have organisations that can ensure this is done with integrity. We take our responsibilities to combat modern slavery seriously as demonstrated by its promotion and adoption of the following policy measures:

– The prevention, detection, and reporting of modern slavery in any part of its business or supply chains is the responsibility of all those working for the SBS or under its control.

– Appropriate due diligence processes must be carried out in relation to modern slavery which may include considering human rights in a sector or country, the type of sector in which a service provider operates, the countries from which services are provided, the nature of relationships with suppliers, and the complexity of supply chain(s).

– All supply chain lines need to be continually risk assessed and managed in relation to modern slavery and any high-risk suppliers audited. SBS’s standard procurement and contract documentation addresses anti-slavery and anti-trafficking.

– SBS encourages anyone to raise any concerns about modern slavery, using its whistleblowing policy if necessary, and will support anyone who acts in good faith.

– SBS’s recruitment, equalities, and remuneration and reward policies and procedures support its efforts to combat modern slavery and human trafficking.

– SBS will continue to develop its commitment to combat modern slavery and human trafficking and will outline such activities within its annual anti-slavery and anti-trafficking statement.

Any breaches of this policy may result in SBS taking disciplinary action against individual(s) and/or terminating its relationship with any organization or supplier.