Sinclair Group Modern Slavery Policy

As a company the Sinclair Group prides itself on the relationships and treatment of our colleagues and customers, we also wish to maintain the same strong relationships with our suppliers and the employees of suppliers who work directly in our business.

In light of general law on employment and human rights and more specifically the Modern Slavery Act of 2015, we are reviewing our current compliance and risks to ensure we have measures in place to prevent bad practices taking place in any part of our business and supply chain.

We have adopted a statement to govern all our business dealings and the conduct of all persons or organisations with whom we contract directly or who we appoint to act on our behalf.

Sinclair Group Human Rights Policy

As part of our culture of strong positive relationships in the way we do business, Sinclair Group operates very high standards in the treatment of all stakeholder groups; customers, manufacturers, suppliers and colleagues. We ensure our behaviour reflects our attitude towards the exploitation of individuals in any form, particularly towards offences under The Modern Slavery Act of 2015. We are committed to opposing modern slavery in all its forms and preventing it by whatever means we can.

We demand the same attitude from all who work for us and expect it from all with whom we do business.

Our attitude towards modern slavery is Zero Tolerance

To underpin our compliance with this policy with practical steps, we intend to implement the following measures: -

• Conduct risk assessments to determine which parts of our business and which of our suppliers are at most risk of modern slavery so that efforts can be focused on those areas.
• Engage with our suppliers to convey to them our Human Rights Policy and to gain an understanding of the measures taken by them to ensure that modern slavery is not occurring in their businesses.
• Where appropriate, as informed by our risk assessment, seek to introduce supplier pre-screening as part of our tender process and self-reporting for our suppliers on safeguarding controls.
• Introduce contractual provisions for our suppliers to confirm their adherence to this policy and accept our right to audit their activities and relationships with their employees, both routinely and at times pf reasonable suspicion.

We will only do business with contractors and suppliers who are able to demonstrate their adherence to our standards and are willing to be audited to ensure standards are maintained. Lastly we have a Whistleblowing Policy where our employees can raise a grievance or make a complaint about any element of their employment. These matters are taken seriously, we fully investigate all points raised and take appropriate action to rectify anything we believe to be unacceptable. We will inform all our employees and employees of subcontractors working in our business of our Whistle-Blowing Policy and the process of raising any concerns, we will deal with any matters raised by our subcontracted employees in the same way as our own employees, we will expect our contractors and suppliers to work with us to rectify any problems encountered.