Modern Slavery & Human Trafficking Statement

This statement sets out our commitment to preventing modern slavery and human trafficking within our business operations and supply chains.

We recognise that modern slavery is a serious criminal offence and a violation of fundamental human rights. We are committed to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls to ensure slavery and human trafficking are not taking place in any part of our organisation or supply chains.

This statement relates to the relevant financial year and is reviewed and updated as necessary.

Sunfish Online Limited is a management consultancy providing advice and client side support for a range of business transformation activities, primarily focused on technology.

The Company operates within the United Kingdom.

Responsibility for anti slavery initiatives sits with the Director, Procurement Practice, who oversees policy development, risk assessment, and due diligence processes to ensure appropriate controls are in place.

The Director, Procurement Practice is responsible for creating and reviewing policies related to modern slavery and human trafficking. Policies are developed in line with best practice within the management consultancy sector and are reviewed regularly to ensure they remain appropriate to the Company’s activities.

We conduct ongoing risk assessments in respect of human rights and modern slavery. This includes reviewing:

• The scope of services provided to clients
• Any material changes within our supply base
• Potential exposure to human rights risks

Where risks are identified, further due diligence is undertaken.

We undertake appropriate due diligence when engaging with suppliers and business partners. This includes:

1. Reviewing new suppliers prior to engagement
2. Conducting regular reviews of existing suppliers
3. Evaluating modern slavery and human trafficking risks
4. Taking appropriate action where performance does not meet expectations, including termination of the relationship if required

We build long standing relationships with suppliers and clearly communicate our expectations regarding ethical standards.

Our approach to identifying and mitigating modern slavery risks is supported by the following policies:

Whistleblowing Policy – We encourage employees, clients and business partners to report any concerns relating to our activities or supply chains. All concerns are taken seriously and investigated appropriately.

Company Code of Conduct – Our Code of Conduct sets out the standards of behaviour expected from employees when representing the Company.

Corporate Social Responsibility Policy – Our CSR policy outlines how we work responsibly with suppliers, clients and local communities.

To ensure a strong understanding of modern slavery risks:

• All staff are required to read and attest compliance with this statement

• Training materials and online resources are provided to maintain awareness of modern slavery and human trafficking risks.

• Staff must confirm they have read and understood the Ethical Trading Initiative Base Code within three months of joining and annually thereafter.

This ensures our people are equipped to identify and report potential concerns.

We measure the effectiveness of our approach through:

• Requiring Director approval for new suppliers following risk assessment
• Ensuring relevant staff complete training on modern slavery and human trafficking
• Ongoing monitoring of supplier performance

These measures help ensure that slavery and human trafficking are not taking place within our business or supply chains.

This statement is reviewed regularly and updated where necessary. The Board of Directors fully endorses this policy and is committed to its implementation.

Approved by: Gilbert Mackay | Director, Procurement Practice | 31 August 2021