Legal

Anti-Slavery Policy

Version 0.03

Contents

  1. Anti-Slavery Policy Statement
  2. Who must comply with this policy?
  3. Who is responsible for this policy?
  4. Your compliance with this policy
  5. How and when to notify in case of non-compliance
  6. Breaches of this policy
  7. Why this matters to Stream
  8. Our supply chain due diligence

1. Anti-Slavery Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Stream Networks are committed to acting ethically and with integrity in our business dealings and relationships and to implementing and enforcing systems and controls to ensure modern slavery is not taking place in our own business or in our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with disclosure obligations we may have under applicable law. We expect the same standards from our contractors, suppliers, and other business partners.

2. Who must comply with this 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, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

3. Who is responsible for this policy?

Stream Networks' Compliance Manager is responsible for this policy.

The Compliance Manager has primary responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and reviewing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

4. Your compliance with this policy

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

5. How and when to notify in case of non-compliance

You must notify the Compliance Manager as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with the Compliance Manager.

6. Breaches of this policy

We may terminate our relationship with individuals and organisations working on our behalf if they breach this policy.

7. Why this matters to Stream

As a business-only technology and telecom provider trusted by public sector bodies, education, healthcare and enterprise customers, Stream Networks recognises that our own integrity depends on the integrity of everyone we work with. Modern slavery has no place in our operations, our supply chains, or the wider industry we operate in — and we hold ourselves and our partners to that standard consistently, not just when it's convenient.

8. Our supply chain due diligence

Stream Networks works with a range of network, hardware and service partners to deliver our connectivity, cloud and communications solutions. As part of our commitment to this policy, we:

  • Assess new suppliers and contractors for modern slavery risk as part of our onboarding process.
  • Include anti-slavery expectations in our contractual terms with suppliers and business partners.
  • Provide guidance to staff on how to recognise and report the signs of modern slavery.
  • Review this policy periodically to ensure it remains effective and reflects current legislation.

This policy is reviewed and approved by Stream Networks' senior leadership team, and the Compliance Manager reports on its effectiveness as part of our wider governance processes.

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