Anti-Slavery and Human Trafficking Policy

Last Updated: June 18, 2025

1. Policy Statement

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, and suppliers.

Snappy-Sites strictly prohibits the use of modern slavery and human trafficking in our operations and productions. We are committed to implementing systems and controls to ensure that modern slavery is not taking place within our organization or in any of our productions. We expect our producers and partners to hold their own staff and contractors to the same high standards.

2. Commitments

Modern Slavery and Human Trafficking

Modern slavery encompasses slavery, servitude, forced and compulsory labor, bonded and child labor, and human trafficking. Human trafficking involves arranging or facilitating the travel of another person with the intent of exploitation. Modern slavery is a crime and a violation of fundamental human rights.

Our Commitments

We are dedicated to upholding the following measures to safeguard against modern slavery:

• We maintain a zero-tolerance approach to modern slavery within our organization and supply chains.
• The prevention, detection, and reporting of modern slavery in any part of our organization or productions is the responsibility of all individuals working for us or on our behalf. Workers and contractors must not engage in, facilitate, or fail to report any activity that might lead to or suggest a breach of this policy.
• We are committed to engaging with stakeholders and producers to address risks of modern slavery in our operations and productions.
• We take a risk-based approach to contracting processes and keep them under review. Where appropriate, we assess whether circumstances warrant specific prohibitions against modern slavery in contracts with third parties. We may also require producers to comply with our Code of Conduct, which outlines minimum standards to combat modern slavery and trafficking.
• Consistent with our risk-based approach, we may require:
  • Employment and recruitment agencies and other third parties supplying workers to our organization to confirm compliance with our Code of Conduct.
  • Suppliers engaging workers through a third party to ensure those third parties adhere to the Code of Conduct.
• As part of our ongoing risk assessment and due diligence processes, we consider whether circumstances warrant supplier audits to verify compliance with our Code of Conduct.
• If we find that individuals or organizations working on our behalf have breached this policy, we will take appropriate action. This may range from seeking remediation for impacted individuals to terminating relationships with those in breach.