A) ORGANISATION

This statement applies to all companies within and associated to Sannam S4 (referred to in this statement as ‘The Group’).

B) ORGANISATIONAL STRUCTURE

Sannam S4 Investment Pte Ltd is the holding company for Sannam S4’s group of companies, including entities in India, the USA and the UK. The Sannam S4 group is managed via the Sannam S4 Investment Pte Ltd Board which meets quarterly and is made up of both executive and non-executive directors and a designated Chairman.

Sannam S4 supports organisations looking to Explore, Enter and Expand into dynamic international markets. These activities can be broadly categorised into advisory and ongoing support activity. The work is largely unseasonal with the exception of peaks in activity as driven by local financial, accounting and compliance and HR regulations in the markets that we operate.

The labour supplied to the Sannam S4 group in pursuance of its operation is carried out in the UK, India and the USA. Sannam S4’s team travel from time to time domestically and internationally as their role requires.

C) DEFINITIONS

Sannam S4 considers that modern slavery encompasses:

  • Human trafficking;
  • Forced work, through mental or physical threat;
  • Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
  • Being dehumanised, treated as a commodity or being bought or sold as property;
  • Being physically constrained or to have a restriction placed on freedom of movement

D) COMMITMENT

Sannam S4 acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Sannam S4 understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

Sannam S4 does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to Sannam S4 in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Sannam S4 strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK, India and the USA, and in many cases exceeds those minimum standards in relation to its employees.

E) SUPPLY CHAINS

In order to fulfil its activities, Sannam S4’s main supply chains include those related to the supply of services to run the business (e.g. HR services, premises, marketing, technology, finance and admin) or services required to supply clients (e.g. market entry and support services in countries in which Sannam S4 does not have a business).

F) POTENTIAL EXPOSURE

Given the nature of our business, Sannam S4 considers its main exposure to the risk of slavery and human trafficking to be in the supply of labour in countries where protection against breaches of human rights may be limited.

In general, Sannam S4 considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

G) STEPS

Sannam S4 carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

Sannam S4 has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Sannam S4 has taken the following steps to ensure that modern slavery is not taking place:

  • Reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery.

H) KEY PERFORMANCE INDICATORS

Sannam S4 has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in Sannam S4 or its supply chains.

Periodic engagement of ‘at-risk’ staff via Sannam S4’s Human Capital Team’s regular Employee Relations activity

I) POLICIES

Sannam S4 has the following policies which further define its stance on modern slavery:

  • Code of conduct
  • Recruitment policy

J) TRAINING

Sannam S4 provides the following training to staff to effectively implement its stance on modern slavery

For our Human Capital and Admin Operations teams in India, training on modern slavery policies.

K) SLAVERY COMPLIANCE OFFICER

Sannam S4 has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Sannam S4 obligations in this regard.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

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