Human Trafficking and Slavery

This is the Suntera Global human trafficking and anti-slavery policy. This policy was last updated on 12th August 2020.

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1. What Does this Policy Cover?
This Human Traffic and Slavery Policy (this “Policy”) exists to set out the responsibilities of Suntera Group Limited and our global subsidiaries (“Suntera”, “us”, “we”, or “our”) with regard to observing and upholding our zero-tolerance position on human trafficking and slavery.
2. Policy Statement

We are committed to conducting our business in an ethical and honest manner and to implementing and enforcing systems that ensure human trafficking and slavery is prevented at all times. Modern slavery is a crime and a violation of fundamental human rights. We recognise that it can take various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and strive to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere within our organisation.

We are also committed to ensuring that there is transparency in our business and that our approach is consistent with our disclosure obligations under all relevant applicable Modern Slavery laws. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

3. Who is covered by this Policy?

This Policy applies to all Suntera employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third-parties), or any of our subsidiaries or their employees, no matter where they are located. This Policy also applies to our Officers, Trustees, Board, and/or Committee members at any level.

In the context of this Policy, ‘third-party’ refers to any individual or organisation we meet and work with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.

Any arrangements Suntera makes with a third-party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to human trafficking and slavery.

4. Mitigating Actions
As part of our initiative to identify and mitigate the risk of human trafficking and slavery practices we have in systems in place to routinely:
  • Identify and assess potential risk areas in our business and supply chains;
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains;
  • Monitor potential risk areas in our supply chains; and
  • Protect any employee or person reporting any suspicions or knowledge of instances of human trafficking or slavery.
5. How to raise a concern

If you suspect that there is an instance of human trafficking or slavery activities occurring in relation to Suntera, you are encouraged to raise your concerns at as early a stage as possible. Please address any concerns to:

Head of Compliance, Suntera Global

Clinch’s House, Lord Street, Douglas, Isle of Man

6. Communication
This Policy and our zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.
7. Record Keeping
We keep detailed and accurate records of all reports made and actions taken in relation to concerns raised regarding human trafficking or slavery.
8. Monitoring and Reviewing
Our internal control systems and procedures designed to prevent human trafficking and slavery are subject to regular audits to ensure that they are effective in practice. Any need for improvements is applied as soon as possible.