Anti-Slavery and Human Trafficking Policy

1. Policy Statement

This policy applies to everyone working for or on behalf of SCT, including employees, directors, contractors, agency staff, consultants, suppliers, and business partners.

SCT is committed to preventing modern slavery and human trafficking in all forms throughout our organisation and supply chain. We operate in accordance with Irish law, including the Criminal Law (Human Trafficking) Act 2008 (as amended), which prohibits trafficking, forced labour, slavery, and servitude, as well as the wider EU and GDPRaligned obligations on ethical business conduct. [gov.ie]

We expect all suppliers and partners to uphold the same high standards and to ensure that their own supply chains are free from exploitation.

2. Understanding Modern Slavery and Human Trafficking

Modern slavery includes:

  • Forced or compulsory labour
  • Bonded labour
  • Servitude
  • Child labour
  • Human trafficking for labour or exploitation

Under Irish law, human trafficking involves arranging or facilitating the movement of a person for the purpose of exploitation. It is a serious criminal offence and a violation of fundamental human rights. [gov.ie]

SCT has zero tolerance for any form of modern slavery.

3. Our Commitments

SCT commits to:

  • Zero tolerance for modern slavery in our organisation or supply chain.
  • Maintaining internal controls to prevent, identify, and report modern slavery risks.
  • Ensuring all employees and partners are aware of their responsibility to report concerns without fear of retaliation.
  • Embedding ethical practices into procurement, supplier management, and contract processes.
  • Meeting our obligations under Irish data protection and employment legislation to safeguard individuals’ rights. [gov.ie]

4. Responsibilities

All SCT staff and representatives must:

  • Never participate in, enable, or ignore any activity linked to modern slavery.
  • Report any concerns immediately through internal reporting channels.
  • Act ethically and comply with this policy and all applicable Irish legislation.

SCT leadership is responsible for:

  • Implementing robust systems for due diligence and risk assessment.
  • Ensuring this policy remains up to date and effective.
  • Engaging with suppliers to uphold the same high standards.

5. Supplier and Contractor Expectations

SCT uses a riskbased approach when assessing suppliers. In line with Irish corporate obligations and good governance guidance, we will:

  • Require suppliers to confirm compliance with SCT’s Code of Conduct.
  • Assess whether contracts should include explicit clauses prohibiting modern slavery.
  • Require confirmation that recruitment agencies and labour providers comply with ethical standards.
  • Request evidence of supplier due diligence where appropriate.
  • Evaluate whether audits or followup actions are required in higherrisk cases.

Where suppliers subcontract labour, they must ensure their subcontractors are also compliant.

6. Due Diligence & Risk Management

As part of our ongoing due diligence processes, SCT will:

  • Review supply chains to identify modern slavery risks.
  • Apply enhanced checks for higherrisk sectors, countries, or labour arrangements.
  • Require corrective actions if concerns are identified.
  • Terminate relationships with suppliers who fail to address breaches or refuse to comply.

Depending on the situation, SCT may consider remediation efforts that best support affected individuals before deciding on contract termination.

7. Reporting Concerns

All staff, contractors, and partners are encouraged to raise concerns about any suspected instance of modern slavery. Reports can be made confidentially, and SCT will ensure there is no retaliation for goodfaith reporting.

8. Review of This Policy

SCT will review this policy annually or sooner if legislative changes require updates.