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SureSkills is committed to improving our practices to combat modern day slavery and human trafficking. SureSkills Limited (“SureSkills”) will continue its efforts to ensure all people are treated with dignity and respect when we are competing for and running projects and activities wherever we work. The company and structure SureSkills is a provider of training, learning services and IT consulting services. SureSkills is an owner managed company which has its head office in Dublin, Ireland. SureSkills is primarily engaged in projects providing technical services to global organisations.

Our company has over 150 employees and operates in the USA, UK and Ireland. Our supply chains; whilst IT technical, Learning and Training services are not known to harbour practitioners of modern day slavery and human trafficking. We are conscious that our supply chains include sub-contractors, suppliers and agency staff who assist in the completion of the projects in each country we operate in. Our policies on modern day slavery and human trafficking We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business, and in so far as is possible, to requiring our suppliers to hold similar ethos. Our slavery and human trafficking policy statements below reflect our commitment to acting ethically and with integrity in all our business relationships. In addition to this we operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

POLICY STATEMENT

Slavery is illegal and a violation of human rights. There are many forms of Modern Slavery including; forced labour, child labour, exploitation, being controlled by an employer, debt bondage, being physically constrained, being sold or treated as a commodity and having restrictions on freedom of movement. These acts involve a person losing their freedom by being exploited by another for personal or commercial gain.

SureSkills has a zero-tolerance approach to Modern Slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships. We will implement and enforce effective systems and controls to ensure Modern Slavery is not taking place in our own business and supply chains. We are committed to ensuring our business is transparent, as such we will comply with the disclosure obligations under the Modern Slavery Act 2015.

SureSkills expects our contractors, suppliers and other business partners to uphold high standards in all business practices; as part of the contracting processes, we include prohibitions against the use of staff sourced from forced, compulsory or trafficked labour, anyone held in slavery or servitude. SureSkills expect their suppliers to hold these high standards. SureSkills is in regular in contact with relevant suppliers to ensure they comply with the Modern Slavery Act 2015, In addition to this, to check compliance, we will be auditing our higher risk suppliers, as determined by our predetermined criteria.

This policy applies to all persons working for, or on behalf of any of our customers, in any capacity. This includes but does not limit the policy applicability to; employees, agency workers, temporary staff, agents, contractors, external consultants, third-party representatives and business partners. This policy does not form part of any employee's contract of employment, and we reserve the right to amend it at any time.

2. RESPONSIBILITY FOR THE POLICY

The SureSkills Executive Leadership Team has overall responsibility for ensuring this policy complies with our customers legal and ethical obligations, and that all those under our control comply with it. The SureSkills Finance Director has primary responsibility for implementing this policy. This includes responsibility for the monitoring of its use and effectiveness, auditing of internal control systems and procedures. The Finance Director working with our Chairperson is also responsible for updating the policy to reflect any changes in legislation.

Management at all levels of SureSkills are responsible for ensuring those reporting to them understand and comply with this policy and, are given adequate and regular training on Modern Slavery. Customers and their employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to grc@suresills.com.

3. COMPLIANCE WITH THE POLICY

You must ensure that you read, understand and comply with this policy. All SureSkills employees are responsible for the prevention, detection and reporting of Modern Slavery in any part of our business or supply chains is. Employees are required to avoid any activity that might lead to a breach of this policy, and the Modern Slavery Act 2015. You must notify your manager OR Function Head as soon as possible if you believe or suspect that, a conflict with, or breach of, this policy has occurred, or may occur, in the future. You can also report any suspected breach by following our Whistleblowing Policy.

Employees are encouraged to raise concerns about suspicions of Modern Slavery in any parts of our business or supply chains at the earliest possible stage (see 3.3). If you are unsure whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any, or all of, the various forms of Modern Slavery outlined in 1.1, follow 3.3.

4. COMMUNICATION AND AWARENESS OF THIS POLICY

This policy is available on the SureSkills website https://www.sureskills.com/Modern-Slavery-Policy. Modern Slavery training, which includes identifying signs of Modern Slavery and reporting suspicions of Modern Slavery with SureSkills supply chains, forms part of the induction process for employees. Refresher training will also be provided as necessary.

Our zero-tolerance approach to Modern Slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them. Suppliers are asked to comply with our Anti-Slavery and Human Trafficking policy from the onset of the relationship. Suppliers who are unwilling to comply will not be on boarded.

5. BREACHES OF THIS POLICY

Any employee who breaches this policy will face disciplinary action. This could result in action up to dismissal in accordance with the. We may terminate our relationship with other employees, suppliers and any other associates working with SureSkills if they breach this policy. Our commitment to combating slavery and human trafficking Any query about this policy statement should be addressed to grc@suresills.com SureSkills Limited.