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 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. 

These policies have been actively overseen and reviewed by the Board and the Sustainability and Ethics Committee.

Modern Slavery Statement

We are committed to identifying and tackling the potential exploitation of vulnerable workers within our Group and our supply chain. We have adopted a risk-based approach and continually assess the adequacy of our anti-slavery measures to provide assurance that we are leveraging our influence to the greatest effect, where it is needed most. Our Modern Slavery Statement was updated and republished in March 2025. Since the introduction of our first Modern Slavery Statement in 2020, we have found no instances of modern slavery within the Group or across our supply chain.

Anti-Bribery and Corruption Policy

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 and related training and procedures are firmly established in our Group and there have been no material incidents to date.

Anti-Discrimination and Diversity Policy

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, and we have a zero-tolerance policy against discrimination and unequal treatment.

Supplier Code of Conduct

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”).

Health and Wellbeing Policy

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.

Sustainability Policy

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 the continuing development of our ESG programme.

Employee Code of Conduct

Our Employee Code of Conduct, which applies to all our colleagues globally, 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 behaviour, relationships at work, ethical standards and avoiding corruption.

Whistleblowing Policy

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 four years.

Acceptable Use of IT Policy

Sirius IT’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to Sirius’s established culture of openness, trust and integrity. Sirius is committed to protecting Sirius's employees, partners and the company from illegal or damaging actions by individuals, either knowingly or unknowingly.

Cyber Security Policy

Cybersecurity remains a priority and is overseen by the IT Committee, which meets regularly and reports quarterly to the Board. We continuously assess our risks and work to mitigate current and emerging threats, with risk and vulnerability management life cycles integrated into our practices. External supply chain risks are also carefully managed and mitigated.

All employees are given training and are tested annually. Compliance with EU and UK GDPR regulations is also constantly reviewed and assured.

We have a comprehensive Information Security Management System 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 guidance and best practices. We have achieved the cybersecurity certificate renewal following our annual penetration test. No material information security breaches have occurred in the last three years.