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. In the last financial year we conducted a full review of our policies, managed by the Asset Management Team, with updates to policies signed off at the Board meeting on 24th March 2023. A summary of our policies follows.


Modern Slavery Statement

We are committed to identifying and tackling the potential exploitation of vulnerable workers within our Group and our supply chain. Our risk-based approach regularly and reliably assesses the effectiveness of our anti-modern slavery measures and ensures that we are leveraging our influence to greatest effect. Our Modern Slavery Statement was updated and republished on 24 March 2023. In the current fiscal year as well as in the past three years, we have not identified any cases of modern slavery within our Group or in our supply chain.

Anti-Bribery and Corruption Policy

We do not tolerate any form of bribery and corruption and uphold applicable laws to prevent bribery and corruption in all jurisdictions in which we operate. We are committed to implementing appropriate and proportionate risk-based protocols to prevent anyone associated with our Company from engaging in 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.

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 guidance and best practices. Compliance with both EU and UK versions of GDPR is also constantly reviewed and assured. A cyber security audit of both Sirius and BizSpace was undertaken in July 2022, with a certificate of assurance awarded.

There is operational responsibility through the IT Committee, which meets regularly and reports quarterly to the Board. We have had no material instances of information security breaches during this financial year or over the last three years

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