In line with Sealand’s dedication to promoting transparency and social responsibility, we have formulated a comprehensive Supplier Code of Conduct. We strive to procure our materials solely from responsible manufacturers and pledge to collaborate with any suppliers encountering challenges in establishing new, compliant systems. While not legally obligated to disclose commitments, we recognize Modern Slavery as a significant issue that every business must confront head-on to foster global progress. Adhering to the highest international standards available, we commit to addressing the stipulations of the UK Modern Slavery Act 2015 ("the Act") and ensuring our supply chain complies with its regulations. We acknowledge the commitments outlined in the Act and endeavor to foster a culture of transparency regarding the provision of goods and services to us. This statement, issued pursuant to section 54 of the Act, constitutes Sealand’s Modern Slavery and Human Trafficking Statement for the financial year ending February 28, 2023.

Despite having no operations in the UK and thus not being subject to this Act, we remain steadfast in upholding the utmost standards of integrity, transparency, and ethics.

We are dedicated to guaranteeing that our supply chain remains free from any form of slavery or human trafficking. We intend to govern all existing and future third-party relationships with a focus on these issues and will not knowingly engage with or support any suppliers involved in slavery.

To fulfil our obligations under the Act, Sealand will:

1. Conduct due diligence procedures to assess our exposure to the risk of slavery; 
2. Request information on third-party suppliers’ working practices and require key suppliers to confirm compliance with the Act; 
3. Communicate our zero-tolerance policy on slavery to potential key suppliers; 
4. Ensure key suppliers adhere to Sealand’s Supplier Code of Conduct, which mandates a review of their supply chain to ensure it is free from modern slavery, and that all representatives conduct business in accordance with the Code; 
5. Communicate to suppliers the requirement for continued self-monitoring and prompt reporting of any violations of the Code;
6.  Incorporate references to slavery and supply chain issues in our supplier engagement process, audit procedures, and contractual arrangements with third-party suppliers.

Through these processes, we aim to identify and mitigate any slavery risks.

Additionally, as part of our commitments under the Act, we are developing an internal policy available to all employees, offering guidance on identifying, managing, and reporting such risks.

The responsibility for ensuring adherence to this policy rests with all employees interacting with third-party suppliers. Employees aware of or suspecting any Act violations must promptly report such conduct to their leaders. Our whistle-blowing policy encourages all employees to raise concerns or disclose information without fear of reprisal.

Key performance indicators used by Sealand to gauge the effectiveness of its modern slavery approach and compliance with the Act include:

1. Effective deployment of internal training to key stakeholders; 
2. Annual reviews of the Act and updated guidance for compliance; 
3. Completion of due diligence procedures on key suppliers; 
4. Ongoing monitoring of key suppliers; 
5. Effective avenues for employees and suppliers to escalate modern slavery concerns.

This statement, subject to annual review and updates as necessary, has been scrutinized by key stakeholders, senior management, and approved by our Board of Directors.

We reiterate our steadfast commitment to the Act and its underlying principles.