Modern slavery policy statement

Updated 15 April 2021

Our commitment

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 to exploit them for personal or commercial gain.

We have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships. We are working to implement and enforce effective and transparent systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chain.

Our supply chain

The majority of our procurement spend is with IT, office and professional service providers rather than the purchase of manufactured goods, therefore we believe the risk of modern slavery in our supply chain is low. However, we will not knowingly work with suppliers who engage in these practices. Through our supplier risk management process we endeavour to safeguard that slavery, forced labour, human trafficking and child labour do not take place in our supply chain and continue to focus on improving applicable policies and processes accordingly.

Further actions

This year, we will raise our employees’ awareness by including modern slavery training as part of our core training modules. Each employee will be asked to read the modern slavery policy and complete the associated training.

We are also in the process of enhancing our supplier due diligence and take on process:

1. By revising our supplier risk management policy.

– We will have a four-tier procurement activity classification system based on key risks the activity poses to Smart. Any new supplier assigned a high or moderate risk tier will have to complete a mandatory supplier due diligence questionnaire. Suppliers assigned a low-risk tier will be required to complete a take-on Request for Information (RFI) form.

– All existing suppliers will be reassessed on contract renewal, assigned a tier and will complete the new due diligence questionnaire or RFI as applicable.

– Due diligence questionnaires will contain questions specifically designed to identify suppliers where the risk of modern slavery in their supply chain is high.

2. By asking suppliers to acknowledge our procurement code of conduct.

– Smart’s procurement code of conduct will reflect our zero-tolerance policy to modern slavery and expectation that the supplier fully complies with the requirements of applicable slavery, forced labour, human trafficking and child labour laws and holds their own suppliers to the same standards.

– Due diligence and RFIs will contain Smart’s procurement code of conduct.

– High and moderate risk tiered suppliers will be required to confirm their commitment to Smart’s procurement code of conduct when completing the due diligence questionnaire.

Our Anti-Slavery Officer (ASO) is the Director of Talent and is responsible for this statement. They can be contacted at [email protected].