ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY

As a Group, Sunbeam Consulting Ltd maintains relationships with many different organisations in its supply chain, as well as directly employing a small number of people. Sunbeam Consulting Ltd has a zero-tolerance approach to modern slavery both within the Group and within its supply chain. We have reviewed our existing compliance and risk management processes following the introduction of the Modern Slavery Act 2015 to determine to what extent measures already exist, and what further measures may be required to prevent slavery and human trafficking taking place in any part of our businesses or in our supply chains. The policy below underpins our approach.

Sunbeam Consulting Ltd respects fundamental human rights and is committed to the principles set out in the United Nations Universal Declaration of Human Rights. We support and respect the protection of human rights within our sphere of influence; in particular the effective elimination of compulsory labour and child labour.

We are committed to opposing modern slavery in all its forms and preventing it by whatever means we can. We demand the same attitude of all who work for us and expect it of all with whom we have business dealings. Our attitude to modern slavery is: zero tolerance.

1. PURPOSE OF THIS POLICY

1. Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the "Act"). Modern slavery can occur in various forms, including servitude, forced or 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. This document sets out the policy of Sunbeam Consulting Ltd with the aim of the prevention of opportunities for modern slavery to occur within its businesses or supply chain. This policy's use of the term "modern slavery" has the meaning given in the Act.

2. As a Group, 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 and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own businesses or those of our suppliers.

2. STEPS FOR THE PREVENTION OF MODERN SLAVERY

1. We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our suppliers and other business partners.

2. Whilst recognising our obligation to set out the steps we have taken to ensure that modern slavery and human trafficking is not taking place in our supply chains, we acknowledge that we do not control the conduct of individuals and organisations in our supply chains. To underpin our compliance with practical steps, we intend to implement the following measure:

   a) Engage with our suppliers both to convey to them our Anti-Slavery and Human Trafficking Policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses and their supply chain;

   b) For our own temporary labour to ask on arrival to make sure that they are in control of their earnings and are not being trafficked.

3. RESPONSIBILITY FOR THE POLICY

1. Ultimate responsibility for the prevention of modern slavery rests with the Group's leadership. The Board of Directors of Sunbeam Consulting Ltd has overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations.

4. ACTIONS TO REPORT MODERN SLAVERY OR HUMAN TRAFFICKING

1. Internal Employees are encouraged to raise any concerns about suspected modern slavery associated with the Group or our suppliers and should do this either through their line manager or by using "Whistle Blower Policy" (details of which can be found in the employee handbook)

2. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

   Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

3. The Group will accept and take seriously concerns communicated anonymously. However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations.

5. BREACHES OF THIS POLICY

1. If an issue is identified with a supplier, we will work with them to prepare a corrective action plan and resolve all violations within an agreed upon time period.

2. We reserve the right terminate our relationship with individuals and organisations in our supply chain if they breach this policy.

6. COMMUNICTION AND AWARENESS OF THIS POLICY

1. Our zero-tolerance approach to modern slavery will be communicated to all suppliers. We will from time to time write to them to confirm they have actions in place to prevent trafficking and slavery abuse.

7. REVIEW

1. Following its initial adoption, this Anti-Slavery and Human Trafficking Policy will be reviewed by the Group's Board of Directors on a regular basis and may be amended from time to time.