pg. 4

"At the outset of any supplier engagement and at periodic intervals during the contractual period, we require appropriate due diligence (driven by an initial materiality assessment of the third party) to be completed. This activity facilitates the assessment of potential risks the third party might pose whilst continuing to service our clients and maintain our compliance with business, legal and regulatory requirements, including those of the Modern Slavery Act 2015."

"We can assess the adequacy of a third party’s processes and risk management procedures through evidential assurance and responses to a series of set questions, which cover the following:

• Basic company information, which includes country of origin and parental hierarchy • Risk and regulatory • Financial crime and financial assessment • Business continuity • Responsible Business aspects, including corporate social responsibility, modern slavery and inclusion & diversity • Fitness and propriety • Information security and data protection • Sub-contractors"

pg. 4

“Our due diligence process provides insight into the third party’s structure, operations, culture, approach and focus on modern slavery, including their own supply chain, human resources, supplier and customer relationships, competitive positioning and outlook. Where we identify any links to countries with an increased risk of modern day slavery we will apply additional scrutiny and challenge to the responses and evidence provided in addition to the standard due diligence requirements which requires our third parties to confirm and, where appropriate to do so, evidence compliance with all local legislation.”

“It requires our third parties to provide information around the activities they undertake to mitigate the risks associated with modern slavery and human trafficking. We also seek to understand where sub-outsourcers or suppliers are used by our third parties, and where appropriate request confirmation of our third parties’ due diligence processes in respect of their own supply chain, or where fourth party suppliers may be used in the delivery of goods and services to SJP. We reserve the right to have direct oversight of our third parties’ supply chains, where the risks posed are significant enough to warrant this. We also request information relating to our third parties’ approach to the welfare of individuals who might be working within their supply chain and the steps our third parties are taking to ensure modern slavery and human trafficking is not taking place within their business operations.”