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Modern Slavery Policy 2022

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​Modern Slavery Policy

Sphere recognises and is committed to upholding responsible and fair business practices. It recognises that the practice of modern slavery is unethical and that there is no place for such activities in its business or that of its supply chain. Sphere acknowledges its responsibilities under the Modern Slavery Act 2015 and will ensure transparency within the organisation, its clients, and its suppliers.

Sphere carries out a due diligence process on all its major suppliers of labour which form part of its supply chain to ascertain their policies on Modern Slavery. It will not deal with any business knowingly involved in slavery or human trafficking.

Policy statement

All staff are required at all times to safeguard and uphold the Company’s core values by operating in an ethical, professional, and lawful manner at all times.

All employees are expected to adhere strictly at all times to the guidelines set out in this Policy. If you are in doubt as to what might constitute a breach of this Policy, refer the matter to one of the directors.

Monitoring compliance

The Board of Directors has primary responsibility for ensuring compliance with this Policy and will review its contents on a regular basis. It is responsible for monitoring its effectiveness and has overall responsibility for ensuring this Policy complies with the Company’s legal and ethical obligations.

Training

The Company will provide training to all employees to help them understand their duties and responsibilities with regard to Modern Slavery. Sphere’s stance on the issue will also be communicated to all business partners at the outset of the business relationship with them and as appropriate thereafter.