1: Introduction

1.1 Policy Overview

This Modern Slavery Policy establishes SEHSS’s stance against modern slavery and human trafficking within all areas of its operations and extended supply chains. It underscores our commitment to ethical business practices and legal compliance, embodying our dedication to social responsibility and human rights.

1.2 Purpose and Commitment

The purpose of this policy is to articulate the responsibilities of SEHSS and its employees, contractors, and business partners in identifying, preventing, and mitigating risks of modern slavery and human trafficking. SEHSS is committed to implementing and enforcing effective systems and controls to safeguard against any form of modern slavery in its corporate activities and supply chains.

2: Scope of Policy

2.1 Applicability

This policy applies globally to all personnel within SEHSS, including senior management, employees, contractors, subcontractors, consultants, and any other third-party representatives engaged in business on behalf of SEHSS.

2.2 Supply Chain Assurance

SEHSS insists that transparency, accountability, and ethical practices are upheld across all operational facets, particularly within our supply chains. We are committed to ensuring all partners and suppliers conform to our high standards regarding human rights and ethical conduct.

3: Definitions of Modern Slavery

3.1 Forms of Modern Slavery

Modern slavery encompasses:

• Forced Labor: Employment against one’s will under the threat of penalty or coercion.
• Human Trafficking: The act of recruiting, transporting, transferring, harboring, or receiving persons through the use of force or other means for the purpose of exploitation.
• Debt Bondage: The use of a debt as a means of keeping a person under control.
• Child Labor: Utilizing the labor of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development.

4: Compliance Measures

4.1 Risk Assessment

SEHSS will conduct regular risk assessments to identify and mitigate risks related to modern slavery in all areas of our business operations, including our supply chains.

4.2 Due Diligence Processes

Comprehensive due diligence processes will be implemented to understand the broader impact of our supply chains and business practices, aimed at ensuring that we and our partners comply with our ethical standards and legal obligations.

5: Responsibilities

5.1 Management Responsibility

Senior management at SEHSS has the responsibility to ensure the effectiveness of this policy through its endorsement, implementation, and regular review. Leaders are expected to foster a culture of integrity and openness where concerns about modern slavery can be raised without fear of retaliation.

5.2 Employee and Contractor Responsibilities

All employees and contractors are required to understand and comply with this policy. Employees are encouraged to be vigilant and to report any suspicions of modern slavery, assured that their reports will be handled with confidentiality and protection.

6: Training and Awareness

6.1 Training Programs

SEHSS will provide training to relevant employees and management who are involved in supply chain management and those who have the potential to encounter modern slavery issues. This training will cover the fundamentals of the Modern Slavery Policy, risk identification, and the steps to follow when concerns arise.

6.2 Awareness Raising

SEHSS will also undertake initiatives to raise awareness about modern slavery risks, the importance of safeguarding human rights, and the methods to report potential violations, both within our organization and in wider society.

7: Reporting and Whistleblowing

7.1 Reporting Mechanisms

SEHSS maintains a secure whistleblowing mechanism allowing anyone to raise concerns about potential breaches of this policy anonymously. All reports will be investigated thoroughly and appropriate actions will be taken.

7.2 Protection for Whistleblowers

SEHSS assures protection for whistleblowers from retaliation. We support an open and transparent environment where all employees feel safe to report violations.

8: Policy Review and Updates

8.1 Regular Reviews

This policy will be reviewed annually to ensure it remains effective and reflective of current laws and organizational commitments. Revisions will be made as necessary to continually enhance our frameworks for combating modern slavery.

Conclusion

SEHSS’s Modern Slavery Policy represents our unwavering commitment to acting ethically and with integrity in all our business relationships. Through the implementation of this policy, SEHSS aims to combat modern slavery and human trafficking, ensuring that we uphold the rights and dignity of every individual affected by our business operations.