This Modern Slavery and Human Trafficking Statement is in response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 29 February 2024.

Sanctions SOS Ltd. (‘the Company’, ‘we’, ‘us’, or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

Sanctions SOS Ltd. has business operations only in the United Kingdom.

We operate in the risk management and compliance sector. The nature of our supply chains is as follows:

We work with a number of key direct suppliers, who provide us with goods, such as equipment for our premises, and services, such as outsourced business processes, IT software, accountancy, and marketing services. These suppliers are predominantly based in the UK and adhere to the UK’s Modern Slavery and Human Trafficking laws.

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

These include the following:

· Recruitment and selection policy – We conduct checks on all prospective employees to verify that they are eligible to work in the UK. For certain roles we also require a Disclosure and Barring Service (DBS) check, when employees are working on particularly sensitive financial crime compliance issues.

· Whistleblowing policy – We operate this policy so that employees are able to raise concerns about how staff are being treated or practices within our business of our supply chains without fear of reprisal.

· Staff code of conduct – We are committed to the fair treatment of all our staff. Our staff code of conduct reflects our core values and expected behaviours. The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery.

· Procurement policy – We want to make sure that potential suppliers are committed to ensuring that slavery and human trafficking is not taking place within their own supply chains. Our procurement policy and supporting procedures set out controls and checks undertaken to help verify this.

We make sure our suppliers are aware of our policies and adhere to the same standards.

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

· Internal supplier audits.

Our due diligence procedures aim to:

· Identify and action potential risks in our business and supply chains.

· Monitor potential risks in our business and supply chains.

· Reduce the risk of slavery and human trafficking occurring in our business and supply chains.

· Provide protection for whistleblowers.

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

· Evaluating the slavery and human trafficking risks of each new supplier.

· Creating an annual risk profile for key suppliers.

· Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.

We do not consider that we operate in a high-risk environment because the majority of our supply chain is based in the UK and in low-risk industries, such as financial services, and internet software and services.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will require that supplier to remedy the non-compliance.

The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

· We will train our staff about modern slavery issues and increase awareness within the Company.

· We will carry out a regular audit of suppliers – 66% of suppliers each year.

The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The Company’s training covers:

· How to identify the signs of slavery and human trafficking.

· What initial steps should be taken if slavery or human trafficking is suspected.

· How to escalate potential slavery or human trafficking issues to the relevant parties within the Company.

· What external help is available.