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MODERN SLAVERY STATEMENT FOR 2021/22

This statement is made on behalf of S.T.I. (U.K.) Ltd. (“STI UK”) and all of its direct and indirect subsidiaries and joint ventures (the "Group") who are committed to conducting business in an ethical manner in compliance with all applicable anti-slavery, human trafficking and migrant labor laws in the countries in which they operate.

This statement is made pursuant to Section 54, Part 6 of the UK Modern Slavery Act of 2015 and sets out steps S.T.I. (U.K.) Ltd., has taken to ensure that slavery and human trafficking are not taking place in our business or throughout any part of our supply chain.

Our Mission
STI UK is an organisation dedicated to being the leading supply chain solutions service provider, creating an outstanding work environment for our employees and delivering unmatched value for our customers while protecting their brands.

Our Policy
As a supplier, STI UK requires all of its Group companies to comply with a Supplier Code of Conduct ensuring fair and ethical workplace standards across our supply chain. The Supplier Code of Conduct addresses human rights, workplace environment, environmental management and business integrity.

Our Practices
STI UK has taken and continues to take a variety of actions to verify the absence of forced labour, slavery and human trafficking, including but not limited to the following:
  • Long Standing Relationships: We build long standing relationships with customers and suppliers who share our values and know our expectations of business behaviour.
  • Due Diligence: We complete due diligence on agents who interact with government actors on our behalf, in order to ensure worldwide adherence to applicable laws.
  • Audits: All operations complete a Supplier Workplace Accountability Audit including but not limited to a physical, onsite audit, acknowledgment of the Supplier Code of Conduct, review of online training material and self-assessment questionnaires.
  • Reporting: We have a corporate wide accountability and reporting mechanism (Ethics Hotline) and require employees to complete a mandatory ethics certification on a yearly basis as permitted by local law and/or collective bargaining agreements.
  • Internal Accountability: STI UK has internal processes and procedures to help confirm that employees and suppliers meet our standards, including internal audits, measurement of key performance indicators and customer business reviews.
  • Labour Monitoring: We pride ourselves on best practice labour monitoring and established ethical practices in each country. All employees are made aware of our policies and how they can be accessed for future reference. Anyone involved in recruitment is trained and required to comply with all applicable legislation and processes to ensure that we remain ethical. We also conduct audits at a local level to identify problems or instances of non-compliance and develop corrective action plans that identify root causes to prevent instances of recurrence.
Our focus on preventing slavery and human trafficking is part of a larger effort to encourage supply chain transparency and accountability. We do not tolerate forced, bonded (including debt bondage) or indentured labour, involuntary prison labour, slavery or trafficking of persons for any purpose. This statement is made on behalf of STI UK and the Group and is approved by its Board of Directors as of January 11, 2021.

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