Spinnaker Global Ltd and Spinnaker Global (Singapore) Pte Ltd (hereafter ‘Spinnaker’) are committed to combatting slavery and human trafficking and to acting with integrity in all its relationships. It has implemented this Anti-slavery and Anti-trafficking Policy reflecting this commitment.

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Policy

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, agents, contractors and suppliers.

Spinnaker strictly prohibits the use of modern slavery and human trafficking in our operations and the services we provide. We have and will continue to be 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 business relationships. We expect that our suppliers will hold their own suppliers to the same high standards.

Commitments

We expect everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

• We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
• The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
• We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
• We take a risk based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risk based approach we will also assess the merits of writing to suppliers requiring them to confirm their compliance with this policy.
• Consistent with our risk based approach we may require:
  • employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance.
  • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the principles of this policy.
• As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance.
• If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action including terminating such relationships