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Modern Slavery Policy

Developed By: HR, Vendor Management, Procurement
Last Reviewed: 03/18/2024

SBM (referred to as “we”, “us”, or “our”) is fully commited to ensuring our operations and supply chains are free from any form of modern slavery. Modern slavery encompasses slavery, servitude, forced labor, and human trafficking. We have zero tolerance for modern slavery and are dedicated to acting ethically and with integrity in all our business dealings.

Scope of the 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, agents, contractors, external consultants, third-party representatives, and business partners.

Policy Statement

We strictly prohibit the use of modern slavery and human trafficking in our operations and supply chain. We expect the same standards from all our suppliers, contractors, and business partners.

We are commited to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place in our business or supply chains.

Due Diligence for Modern Slavery and Human Trafficking

As part of our commitment to ensure there is no modern slavery in our supply chain, we conduct due diligence on new suppliers before allowing them to become a preferred supplier.

This due diligence includes an online search to ensure that a particular organization has never been convicted of offenses relating to modern slavery and, where feasible, an audit of their working practices and environment.


Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labor.

Suppliers must ensure that their goods and services are produced in compliance with all laws and regulations related to the prohibition of modern slavery and human trafficking.

If we believe or have reason to believe that a supplier is involved in modern slavery, we will not enter into a business relationship with them. Existing relationships will be reviewed and potentially terminated.


We encourage all our staff, suppliers, and customers to report any suspicion of modern slavery or human trafficking without fear of retaliation.

Any staff, supplier, or customer who believes or suspects a breach of this policy has occurred or may occur must notify their manager or report it in accordance with our reporting procedures.

Training and Awareness

All employees receive training on this policy as a part of their onboarding process.

We regularly review our risks in this area using relevant key performance indicators, such as training completion rates.


This policy will be reviewed regularly and may be amended at any time. We will monitor its use andeffectiveness and update it as necessary.


By engaging with us, suppliers and contractors are certifying that they adhere to this policy or have in place an equivalent policy that is at least as stringent as ours.