Modern Slavery Policy

1 March 2025

Scope

This policy applies to all individuals working for Smardt or on our behalf in any capacity; this includes directors, officers, employees, consultants, representatives, distributors, agents and contractors, across all regions in Asia, North America, Oceania and Europe.

Position

Smardt is committed to conducting business ethically and sustainably. We recognize the importance of upholding human rights and ethical standards in all aspects of our operations. Smardt has a zero-tolerance approach to modern slavery within our operations and supply chain. All new and existing employees receive training on modern slavery and how to identify the risks of modern slavery within Smardt’s business; and Smardt’s supply chain and procurement teams conduct due diligence on existing and new suppliers to ensure compliance with anti-modern slavery practices; and Smardt works diligently on ensuring its hiring practices.

As required by law, we will report on our efforts to combat modern slavery through annual statements, aligning primarily with the requirements of the Fighting Against Forced Labour and Child Labour in Supply Chains Act 2023 (Canada).

Our ongoing commitment towards preventing and addressing modern slavery in the countries we operate in includes the following.

Adherence to Laws and Standards

Smardt aims to adhere to the laws and standards concerning modern slavery, including the Modern Slavery Act 2018 (Australia), Fighting Against Forced Labour and Child Labour in Supply Chains Act 2023 (Canada), Prevention of Human Trafficking Act 2014 (Singapore), Ratification of the Protocol of 2014 to the Forced Labour Convention 1930 (Malaysia), and the Trafficking Victims Protection Act 2000 (USA).

Selecting Responsible Suppliers

Smardt uses a protocol for selecting suppliers who align with our approach and practice against modern slavery.

Monitoring and Mitigating

We monitor our supply chain process for potential modern slavery risks and if found, action further training, requirements for change and where necessary, termination of relationship.

 

All employees must review the training and awareness materials on modern slavery and report suspected violations of this policy through their respective managers or to the risk management team. Smardt encourages all employees, suppliers, and other stakeholders to report any concerns or suspicions of modern slavery through its whistleblower platform located on its website and internal systems. Willful violations of this policy will result in disciplinary action, which may lead to the termination of employment or contract.

 

This policy will be reviewed annually to ensure its effectiveness and relevance, and updates will be made on annual basis to reflect changes in laws, standards, or business needs.