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We have a clear set of policies that are available to all our external stakeholders and promoted to all employees via the employee handbook, our monthly impact newsletter and the training and development programme. A summary of our policies follows. These policies have been actively overseen and reviewed by the Board, the Sustainability and Ethics Committee and the asset management team.
If you want more information about how the Sirius Real Estate Board operates, please refer to our Governance page.
Sirius is committed to identifying and tackling the potential exploitation of vulnerable workers within the Group and our supply chain. Sirius has adopted a risk-based approach and continually assesses the adequacy of the anti-slavery measures to provide assurance that we are leveraging our influence to the greatest effect. The Modern Slavery Statement was republished on 24 March 2023. We have found no instances of modern slavery within the Group or across our supply chain in the past financial year, nor over the last three years.
We uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we conduct business. We take a zero tolerance to all forms of bribery and corruption, and we are committed to maintaining proportionate, risk-based procedures designed to prevent persons associated with our business from undertaking such conduct. The Anti-bribery and Corruption Policy, training and procedure are now embedded across the Group and there have been no material cases to date.
We value diversity in our structure, ways of working and ways of thinking. We fully recognise that diversity means a wealth of ideas, creativity, enrichment and growth. Differences in terms of origin, gender, age, sexual orientation, religion or ideology are met with the highest acceptance and appreciation. We expressly declare that we will not discriminate against any person on the grounds of origin, gender, religious belief, disability, age, sexual orientation and identity, or other physical characteristics. We want to promote diversity, prevent unequal treatment and create equal opportunities. We have a “zero tolerance policy” against discrimination and unequal treatment.
We see ourselves as a business partner with integrity, reliability and a sense of responsibility. We endeavour to make sure that our actions are held to the highest quality standards, and we expect our trade and business partners to be subject to the same standards. We believe our responsibility can only be sustainable if our business partners share and are compliant with the requirements of our guidelines. Our Supplier Code of Conduct is based on the United Nations Global Compact (“UNGC”), the International Labour Organisation (“ILO”) and the Universal Declaration of Human Rights (“UDHR”).
We are responsible for ensuring that the health of our employees does not suffer as a result of the work they are required to conduct or the working conditions they are required to work in. We are very much aware of this responsibility and take measures to preserve, protect and strengthen both the physical and mental health of our employees.
We are committed to operating in a sustainable and economically responsible way and look to achieve that through governance, social and environmental policies. These are deeply embedded in the management of the Company and ensure the highest standards of business conduct. Our actions are shown through our sustainability framework and our continuing development of our ESG programme.
We are committed to the highest standards of openness, integrity and accountability and we do everything possible to prevent and deter misconduct and violations of law within the Company. We have an “Open Door Policy” and a tailored email address to make it as easy as possible for employees as well as persons who are in contact with Sirius on all business levels to be able to report possible misconduct without being exposed to the risk of having to fear disadvantages in their professional or private life. There have been no instances of whistleblowing within the Group or across our stakeholders during this financial year, nor over the last three years.
Our code of conduct policy defines the ways of working within our organisation. It sets out what we expect from each other at work when it comes to important things like integrity, office behaviours, relationships at work, ethical standards and avoiding corruption.
All information above correct as of 27 March 2023.
Cyber Security Policy
Sirius prioritises cyber security and resilience with representation at Board level. We are continuously assessing our risks and working to mitigate current and emerging threats, with risk and vulnerability management life cycles integrated into our cyber practices. External supply chain risks are also carefully managed and mitigated. Internal cyber training is given to all Sirius employees, including the Sirius Senior Management Team, and tested annually.
There is a comprehensive Information Security Management System (“ISMS”) in place supported by the Company’s Information Security Policies. These policies are mapped to the UK Government’s Cyber Essentials scheme and comply with the UK Government’s National Cyber Security Centre (“NCSC”) guidance and best practices. Compliance with both EU and UK versions of GDPR is also constantly reviewed and assured. The last audit of cyber security was undertaken by a CREST accredited company in December 2021.
There is operational responsibility through the IT Committee, which meets regularly and reports quarterly to the Board. We have had zero instances of an information security breach during this financial year and over the last three years.
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