Modern Slavery Policy

Introduction​

Slavery is a term used to include slavery, servitude, forced and compulsory labour, bonded and child labour, and human trafficking. Victims are coerced, deceived, and forced against their free will into providing work or services. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited.​

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Slavery and human trafficking are illegal and violate fundamental human rights.​

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Forms of modern slavery may include but are not limited to, withholding of passports, being forced to work against a person’s will, depending on the employer for housing, food, and other necessities, being recruited through some form of debt arrangement, such as an advance or loan, and limitations on movement of workers.​

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​Sirius not only prohibits the use of modern slavery and human trafficking in our operations and supply chain but is actively engaged in helping Government Agencies to combat the perpetrators of these crimes many of which originate overseas.​

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​We are committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains.​

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​We expect that our suppliers will hold themselves and their own suppliers to the same high standards.​

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​​We seek to ensure that our partners and affiliates have similarly high standards, respect local laws and customs along with meeting international laws and regulations and we will never knowingly deal with any organisation which is connected to slavery or human trafficking.​

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Business and Organisation Overview

Sirius currently employs people only in the UK and one of the most important parts of our onboarding process is to ensure that each employee has the legal right to work here,​

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​As part of our commitment to combating modern slavery, and to conduct business in an ethical and transparent manner, along with mitigating risk of non- compliance, within our organisation we also have the following related policies:​

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Whistleblowing​

​Bullying​

​Equal Opportunities​

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​​Our policies also invite all staff to contribute to the development of policies and provide suggestion as to how the group may improve its governance and risk management framework, processes and controls.​

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​​Our whistleblowing policy provides guidance for individuals who wish to report any concerns or potential violations of our policies, including our anti-slavery and human trafficking policy. We are pleased to confirm that no incidents have been raised or reported to date.​

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​We operate to high ethical business, employment, and recruitment standards. We recognise that responsible recruitment is an essential tool in combatting modern slavery and preventing human trafficking. Our internal recruitment standards acknowledge the importance of robust recruitment practices and serve as a reference point for management and employees.​

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​​In order to minimise our exposure to risks that may arise in relation to slavery and human trafficking, we always aim to recruit staff directly and do not make frequent use of temporary workers sourced through an intermediary or employment agency.​

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​​Our policies are reviewed and updated regularly to confirm content remains relevant and consistent with the Company's strong commitment to human rights.​

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Risk Management and Compliance

Given the small size of the company and the thorough due diligence process used in the hiring of each employee (interview process, use of BPSS etc.), the risk of an employee being the victim of trafficking or modern slavery is believed to be low.​

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​​Nevertheless, we adopt a zero tolerance approach to these matters we will not tolerate slavery or human trafficking within our supply chains. Any allegations made about modern slavery within the company or our wider supply chain are escalated internally and investigated without undue delay. Depending on the severity of the violation, potential actions available range from; discussions with suppliers around remediation and/or termination of the contract.​

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​While modern slavery can be found among any population, we recognise that certain groups are particularly vulnerable to the risks of modern slavery, including:​

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​Domestic and foreign migrant workers​

​Vulnerable populations (e.g., refugees)​

​Young or student workers​

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​​If and when we use third-party agents and suppliers then we wil ensure that they maintain the same standards - to conduct robust checks on any potential new employee, including eligibility to work in the relevant country, to safeguard against human trafficking or individuals being forced to work against their will.​

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​​Sirius is proud of its culture and corporate ethos, and the collaborative relationships our staff actively maintain with customers and suppliers externally. Our organisation’s culture and the approach we take when dealing with clients, partners, advisors and other third parties has been instrumental in ensuring that we have low levels of staff turnover and few changes in the supply chain.​

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​We understand that the COVID-19 pandemic has created, and continues to create global economic and social disruption, putting vulnerable groups identified above at greater risk of exploitation. The company recognises that the ongoing pandemic will likely exacerbate underlying factors driving modern slavery, including poverty, limited access to decent work opportunities, lack of quality education and the prevalence of the informal economy.​

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Training

The company’s formal training and induction processes for new staff are firmly established across the group. The standard and behaviours expected of our employees are detailed within a number of policies and codes of conduct, in addition to those listed above. All new employees have access to the employee policies required as part of induction and training as required.​

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​Management and support staff remain mindful of their duty and legal obligation to escalate any matters of concern in relation to human rights abuses, in line with company policies. All our employees are encouraged to identify and report any potential breaches of the organisation’s policies within the wider understanding of whistleblowing.​

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Commitment and performance

Having considered a range of factors, including the nature of our products, the sector in which we operate, and the various policies and procedures in place, we believe that the company is at low risk of exposure to slavery and human trafficking.​

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​We are not aware of any areas of our operations and supply chain where there has been a breach of the Modern Slavery Act 2015. Recognising that the human rights risks may change over time as the business enterprise’s operations and operating context evolve, we will continue to:​

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​Re-evaluate the exposure to the risk of modern slavery occurring in our supply chain​

​Review and enhance our governance and risk management frameworks​

​Apply appropriate risk-based due diligence processes to mitigate the risk of non-compliance with the Act.​

​Continually review our induction and training programmes to support our zero-tolerance approach to human rights abuses.​

​Continue training to our executive team to build on their understanding.