Global Ethical Sourcing and Modern Slavery Policy

Purpose and Scope

At Surgo, we are committed to conducting our business operations responsibly, ethically, and in full compliance with all applicable laws and international standards. We recognize our responsibility to protect the rights and dignity of all individuals engaged in our ecosystem, including the buyers and sellers. The purpose of this Global Ethical Sourcing and Modern Slavery Policy is to articulate our unwavering commitment to ethical sourcing practices and to prevent and combat modern slavery in all its forms within the jurisdiction of South Africa.

This policy applies to all aspects of Surgo’s operations, both within South Africa and in connection with any global activities. It encompasses the entire supply chain, including, but not limited to, all suppliers, contractors, buyers, and sellers engaged in providing and delivering goods or services. This policy sets forth our expectations and principles for ethical sourcing and modern slavery prevention, and it is binding upon all employees, management, contractors, suppliers, buyers, and any other parties associated with our operations.

Legal and Regulatory Compliance

Compliance with South African Laws and Regulations:

Surgo is fully committed to upholding the laws and regulations of the Republic of South Africa that pertain to labour rights, human rights, and related matters. This includes, but is not limited to, adherence to the following South African legal frameworks:

Labour Relations Act, 1995: We acknowledge our obligations under the Labour Relations Act, 1995, and commit to respecting the rights of all employees, buyers, sellers, and contractors engaged within Surgo. We will ensure that all employment relationships comply with the provisions of this act.
Basic Conditions of Employment Act, 1997: We recognize the importance of adhering to the Basic Conditions of Employment Act, 1997, which sets out the minimum terms and conditions of employment. Surgo is dedicated to ensuring that all workers receive fair and lawful employment conditions.
Occupational Health and Safety Act, 1993: We prioritize the safety and well-being of all individuals involved in our operations, and we are committed to complying with the Occupational Health and Safety Act, 1993, by providing a safe and healthy working environment.

Compliance Monitoring and Accountability:

Surgo is committed to ensuring strict compliance with all relevant South African laws and international standards. To achieve this, we will:

Establish mechanisms for ongoing monitoring and assessment of our operations and supply chain to identify and mitigate any potential non-compliance with these laws and standards.
Enforce appropriate consequences for violations of this policy, in accordance with applicable legal requirements and our internal procedures.
Collaborate with relevant authorities, governmental bodies, and stakeholders to promote compliance and address any potential issues or concerns related to ethical sourcing and modern slavery.

Through these efforts, we will maintain the highest level of legal and regulatory compliance within the jurisdiction of South Africa and demonstrate our dedication to ethical business practices and the protection of human rights.

Commitment and Leadership

At Surgo, we are unwavering in our commitment to conducting our business with the utmost ethical integrity and social responsibility. We recognize the importance of ethical sourcing practices and the imperative to eradicate modern slavery in all its forms within the jurisdiction of South Africa. We firmly believe that our actions as an organisation have the power to make a positive impact on the lives of buyers, sellers, and all stakeholders involved in our operations.

Leadership and Accountability:

We acknowledge that our commitment to ethical sourcing and modern slavery prevention requires strong leadership and accountability at every level of our organization. To this end, we pledge to:

Senior Management Commitment: Our senior management team, including our CEO and executive leadership, fully supports and champions the principles and objectives outlined in this policy. They are accountable for ensuring its successful implementation and integration into our corporate culture.
Stakeholder Engagement: We actively engage with our stakeholders, including buyers, sellers, clients, investors, and the public, to seek their input and feedback on ethical sourcing and modern slavery issues. We believe that collaboration and dialogue are essential for meaningful progress.
Training and Awareness: We invest in comprehensive training programs and awareness campaigns to educate our employees, contractors, and suppliers about the importance of ethical sourcing and modern slavery prevention. We empower our teams to recognize and address potential risks.
Transparency and Reporting: We are committed to transparency in our operations. We will regularly communicate our progress and efforts in implementing this policy to stakeholders through clear and accessible reporting mechanisms. We will also disclose any challenges or setbacks we encounter.
Compliance and Enforcement: Our compliance with this policy is non-negotiable. We will enforce it consistently, and those who violate its principles will be held accountable, in accordance with applicable legal requirements and internal procedures.
Continuous Improvement: We recognize that the fight against modern slavery is an ongoing endeavor. We will continually review, update, and improve this policy to adapt to changing circumstances and emerging best practices.
Third-Party Verification: To enhance accountability and transparency, we may engage independent third-party auditors to verify our compliance with this policy and to provide additional assurance to stakeholders.

In demonstrating our leadership and commitment, we reaffirm our dedication to ethical sourcing and the eradication of modern slavery within Surgo under South African jurisdiction. We understand that ethical business practices are not merely aspirational but essential for the well-being of individuals, the credibility of our organisation, and the betterment of society.

Risk Assessment

At Surgo, we are committed to identifying, assessing, and mitigating the risks associated with unethical sourcing practices and modern slavery within our operations and supply chains. Our dedication to these principles is central to our responsibility towards buyers, sellers, and other stakeholders engaged within the South African jurisdiction.

Risk Identification:

Supply Chain Analysis: We conduct thorough assessments of our supply chain to identify potential risks related to modern slavery, forced labour, and other unethical practices. This analysis includes the evaluation of all suppliers, contractors, and subcontractors, whether domestic or international.
Worker Vulnerability: We recognize the vulnerability factors that workers may face, such as economic insecurity, lack of bargaining power, and limited access to social protections, these factors are considered in our risk assessment.
Geographic and Sectoral Risks: We assess geographic regions and specific industry sectors where modern slavery risks are known to be higher, considering local laws and conditions.

Risk Evaluation:

Risk Severity: We evaluate the severity of identified risks in terms of their potential impact on workers and the integrity of our organisation. This assessment considers factors such as the nature of the risk, the number of individuals affected, and the potential harm caused.
Likelihood of Occurrences: We assess the likelihood of identified risks materializing within our operations and supply chain. This evaluation considers factors such as historical data, industry trends, and contextual factors.

Risk Mitigation:

Preventative Measures: Based on our risk assessments, we implement preventive measures to reduce the likelihood of modern slavery and unethical practices. These measures may include enhanced due diligence, rigorous supplier audits, and the development of robust contractual clauses.
Worker Empowerment: We take steps to empower workers by providing information, training, and resources to recognize and report potential instances of modern slavery or unethical practices.
Continuous Monitoring: We establish ongoing monitoring processes to detect and respond to emerging risks. This includes regular evaluations of our supply chain, supplier compliance, and external factors that may impact our risk landscape.
Remediation: In cases where modern slavery or unethical practices are identified, we take swift and appropriate remediation actions to address the issues, support affected individuals, and prevent recurrence.

Risk Reporting and Communication:

Internal Reporting: We encourage employees, contractors, and suppliers to report any suspected instances of modern slavery or unethical practices within our organisation. We have mechanisms in place to protect whistle-blowers.
Stakeholder Communication: We communicate our risk assessment findings, actions taken, and progress in mitigating modern slavery risks to our stakeholders, including workers, clients, investors, and the public.

Through this comprehensive risk assessment process, we are dedicated to minimizing the occurrence of modern slavery and unethical sourcing practices within our organisation. We recognize that proactive risk assessment and mitigation are essential components of our commitment to ethical sourcing and modern slavery prevention within South African jurisdiction.

Due Dilligence

At Surgo, we recognize the importance of conducting due diligence to identify, prevent, and mitigate the risks of modern slavery and unethical sourcing practices within our operations and supply chains. Our commitment to due diligence is integral to upholding the highest ethical standards and protecting the rights and dignity of all individuals engaged within our organisation under the jurisdiction of South Africa.

Supplier and Contractor Assessments:

Risk-Based Approach: We employ a risk-based approach to identify suppliers, contractors, and subcontractors that may pose higher risks related to modern slavery. This includes an evaluation of geographic, sectoral, and contextual factors.
Supplier Onboarding: Before engaging with new suppliers or contractors, we conduct due diligence assessments to ensure they align with our ethical sourcing principles and adhere to applicable labour laws and regulations.
Regular Audits: We conduct regular audits and reviews of existing suppliers and contractors to assess their ongoing compliance with our ethical sourcing and labour rights standards.

Worker Rights Audits:

Worker Surveys: In addition to supplier assessments, we engage with workers through surveys to gain insights into their working conditions, rights, and any potential concerns related to modern slavery or unethical practices.
Anonymous Reporting: We provide mechanisms for workers to report any grievances or concerns anonymously, ensuring that they can freely communicate their experiences and observations.

Contractual Requirements:

Ethical Sourcing Clauses: We include specific ethical sourcing and modern slavery prevention clauses in our contracts with suppliers and contractors. These clauses outline our expectations and requirements related to labour rights, ethical conduct, and compliance with applicable laws.
Consequences for Non-Compliance: Contracts stipulate the consequences of non-compliance with our ethical sourcing and modern slavery policy, which may include termination of the business relationship.

Third-Party Verification:

Independent Auditors: We may engage independent third-party auditors to verify supplier and contractor compliance with our ethical sourcing and modern slavery standards. These audits provide an additional layer of assurance and transparency.

Continuous Improvement:

Remediation and Improvement: When non-compliance or risks are identified, we take immediate remediation actions and collaborate with suppliers, contractors, buyers, sellers, and workers to implement necessary improvements.
Ongoing Monitoring: We continuously monitor our supply chain and organisation to detect and address emerging risks and ensure sustained compliance with our ethical sourcing and modern slavery policy.

Through our robust due diligence processes, we are committed to promoting ethical sourcing and modern slavery prevention within our platform. We believe that due diligence is a fundamental step in safeguarding the rights and well-being of workers and all individuals associated with our platform under South African jurisdiction.

Supplier and Contractor Engagement

We consider the engagement of suppliers and contractors to be a critical component of our commitment to ethical sourcing and the prevention of modern slavery within our organisation. We believe that responsible and ethical partnerships with our suppliers and contractors are essential to achieving our goals and upholding our ethical standards.

Ethical Sourcing Expectations:

Alignment with Our Principles: We require all suppliers, contractors, and subcontractors to align with our ethical sourcing principles, which include respect for human rights, labour rights, and compliance with all applicable laws and regulations.
Transparency: Suppliers and contractors are expected to provide transparent and accurate information about their operations, labour practices, and supply chains to ensure that we can assess compliance effectively.

Supplier and Contractor Assessments:

Due Diligence: Before entering into any new business relationship, we conduct due diligence assessments to evaluate the ethical conduct and compliance of potential suppliers and contractors with our ethical sourcing and modern slavery policy.
Regular Audits: We conduct periodic audits and reviews of existing suppliers and contractors to ensure ongoing compliance with our ethical sourcing standards. These audits may include assessments of working conditions, labour practices, and supply chain transparency.

Ethical Sourcing Clauses:

Incorporation into Contracts: We include specific ethical sourcing and modern slavery prevention clauses in our contracts with suppliers and contractors. These clauses outline our expectations and requirements related to labour rights, ethical conduct, and compliance with applicable laws.
Contractual Commitment: Suppliers and contractors are required to commit to adhering to our ethical sourcing and modern slavery policy throughout the duration of their engagement with Surgo.

Consequences for Non-Compliance:

Enforcement: Contracts stipulate the consequences of non-compliance with our ethical sourcing and modern slavery policy. Depending on the severity of the violation, consequences may include corrective actions, termination of the business relationship, and potential legal action.

Continuous Improvement and Collaboration:

Remediation: In cases where non-compliance or concerns arise, we work collaboratively with suppliers, contractors, and subcontractors to implement necessary remediation measures, with a focus on preventing recurrence.
Supplier and Contractor Feedback: We encourage open communication and feedback from our suppliers and contractors regarding their experiences and insights into ethical sourcing practices. This feedback helps us improve our policies and processes continually.

Through the engagement of responsible and ethical suppliers and contractors, we demonstrate our commitment to ethical sourcing and modern slavery prevention. We believe that these partnerships are fundamental to ensuring the wellbeing and rights of workers and all individuals associated with our organisation.

Worker Rights and Protections

We are dedicated to upholding the rights and ensuring the protection of all individuals engaged in our organisation, operating under the jurisdiction of South Africa. We recognize that the dignity, safety, and well-being of workers are paramount, and we are committed to safeguarding these rights throughout our operations.

Fair and Ethical Treatment:

Non-Discrimination: We strictly prohibit discrimination in any form, including but not limited to race, gender, religion, age, disability, sexual orientation, or any other characteristic protected by law. Workers shall be treated with fairness, respect, and dignity always.
Freedom from Harassment: We maintain a zero-tolerance policy for any form of harassment or abuse, including verbal, physical or psychological harassment. Workers have the right to work in an environment free from harassment and intimidation.

Fair Compensation and Working Conditions:

Fair Compensation: We are committed to ensuring that workers receive fair and just compensation for their services, consistent with the terms of their employment agreements and all applicable legal requirements.
Safe Working Conditions: We require that all parties involved in our organisation provide workers with a safe and healthy working environment.

Freedom from Forced Labour and Child Labour:

Zero Tolerance: We strictly prohibit the use of forced labour, child labour, or any form of compulsory labour within our operations and supply chains, consistent with international standards.

Whistle-blower Protection:

Reporting Mechanisms: We provide clear and accessible mechanisms for employees to report any violations of their rights or concerns regarding unethical practices, including modern slavery, without fear of retaliation.
Confidentiality and Protection: We maintain the confidentiality of workers who report concerns and protect them from any adverse consequences for raising genuine concerns.

Training and Awareness:

Education and Training: We invest in education and training programs to enhance the awareness and understanding of worker rights and protections among workers and our employees.

Continuous Improvement:

Feedback and Improvement: We actively seek feedback from employees to identify areas for improvement in our policies, practices, and working conditions. We are committed to making continuous enhancements based on this feedback.

Through these measures, we affirm our dedication to promoting and protecting the rights of employees. We understand that upholding employee rights and protections is not just a commitment but an ethical imperative that ensures the dignity and well-being of all individuals associated with our organisation.

Training and Awareness

We understand that knowledge and awareness are fundamental to the successful implementation of our ethical sourcing and modern slavery prevention efforts. We are committed to ensuring that all stakeholders, including employees, contractors, and workers, have access to the necessary training and awareness programs to promote ethical conduct and human rights protection.

Education and Training:

Employee Training: We provide comprehensive training to our employees to ensure they understand the principles outlined in our ethical sourcing and modern slavery policy. This training includes information on identifying and addressing modern slavery risks and unethical practices.
Contractor Engagement: We actively engage with our contractors to ensure they are informed about our ethical sourcing expectations. We may provide training and resources to help them align with our standards and compliance requirements.
Employee Awareness: We offer resources and training materials to educate employees about their rights and protections under our ethical sourcing and modern slavery policy this includes information on how to identify and report potential violations.

Regular Updates and Communication:

Policy Communication: We regularly communicate our ethical sourcing and modern slavery policy to all stakeholders, ensuring they are aware of its existence, importance, and objectives.
Transparency: We maintain transparency in our operations by sharing information about our progress in implementing the policy and our efforts to combat modern slavery and unethical practices.

Reporting Mechanisms:

Whistle-blower Protection: We establish clear and confidential reporting mechanisms that enable employees, contractors, suppliers, and workers to report any concerns related to modern slavery or unethical practices. We protect whistle-blowers from retaliation.

Awareness Campaigns:

Awareness Initiatives: We initiate awareness campaigns and activities to foster a culture of ethical conduct and human rights protection within Surgo. These initiatives may include workshops, seminars, and awareness-raising events.

Continuous Learning and Improvement:

Feedback and Evaluation: We actively seek feedback from stakeholders to assess the effectiveness of our training and awareness programs. We use this feedback to make continuous improvements and adjustments to our initiatives.

Through our commitment to education, training, and awareness, we aim to empower all individuals associated with our organisation, to recognize, prevent, and address modern slavery risks and unethical sourcing practices. We believe that informed and engaged stakeholders are essential partners in our efforts to promote ethical conduct and protect human rights within our organisation.

Reporting Mechanisms

We prioritize transparency and accountability in our commitment to ethical sourcing and the prevention of modern slavery. We are dedicated to providing clear and accessible reporting mechanisms that enable all stakeholders, including employees, contractors, suppliers, and workers, to report concerns related to modern slavery, unethical sourcing practices, or violations of our ethical sourcing and modern slavery policy.

Whistle-Blower Protection:

Confidential Reporting: We maintain confidential reporting channels that allow individuals to report concerns or violations related to modern slavery or unethical practices without fear of retaliation.
Protection from Retaliation: We are committed to protecting whistle-blowers from any adverse actions or retaliation because of their reports. Retaliation against those who report in good faith is strictly prohibited and subject to disciplinary action.

Accessible Reporting Channels:

Multiple Reporting Options: We provide multiple reporting options to accommodate the preferences and comfort levels of individuals. Reporting can be done in person, through designated email addresses, or online platforms.

Transparent Reporting Process:

Acknowledgement of Reports: Upon receiving a report, we acknowledge its receipt promptly, assuring the reporter that their concern is being taken seriously.
Investigation and Follow-Up: We initiate a thorough and impartial investigation process to assess the reported concern. Upon completion of the investigation, we take appropriate actions to address the issue and prevent its recurrence.

Communication and Feedback:

Communication with Reporters: We maintain open and ongoing communication with the individual(s) who have reported concerns, providing updates on the status of the investigation and resolution process.
Feedback and Closure: Once the matter is resolved, we provide feedback to the reporter regarding the actions taken and the closure of the case.

Reporting Training:

Awareness and Training: We provide training and awareness programs to educate all stakeholders about the availability and use of our reporting mechanisms. This includes informing them about the importance of reporting and the protections in place.

Through these robust reporting mechanisms, we aim to foster a culture of accountability, transparency, and ethical conduct within Surgo. We believe that the active involvement of stakeholders in reporting potential violations is crucial to the success of our ethical sourcing and modern slavery prevention efforts.

Investigation and Remediation

We are fully committed to ensuring the highest standards of ethical conduct and the eradication of modern slavery within our organisation. We understand that investigations and effective remediation are crucial elements in addressing any potential breaches of our ethical sourcing and modern slavery policy.

Reporting and Detection:

Reporting Mechanisms: We maintain accessible and confidential reporting mechanisms to allow stakeholders, including workers, employees, suppliers, and contractors, to report concerns or potential violations related to modern slavery or unethical sourcing practices.
Detection and Identification: We actively monitor, investigate, and verify any reports or suspicions related to modern slavery within our organisation.

Thorough Investigation:

Immediate Action: Upon receiving a report or identifying a potential violation, we initiate a prompt and thorough investigation to assess the situation.
Specialized Teams: Our investigation may involve specialized teams or external experts to ensure a comprehensive and impartial assessment.
Evidence Collection: We gather all relevant evidence, interview involved parties, and conduct site visits or audits, as necessary, to determine the scope and severity of any potential violations.

Corrective Action and Remediation:

Corrective Measures: If a violation or non-compliance is confirmed, we take immediate corrective action to address the issue. This may include, but is not limited to, discontinuing business relationships with non-compliant parties, revising contracts, and implementing new controls.
Support for Victims: In cases where modern slavery or unethical practices have caused harm to individuals, we provide support and assistance to affected parties. This may include access to legal, medical, or psychological support, as needed.
Prevention of Recurrence: We implement robust measures to prevent the recurrence of violations, including improved due diligence, training, and monitoring procedures.

Transparency and Reporting:

Transparency: We maintain transparency throughout the investigation and remediation process, ensuring that relevant stakeholders are informed of the progress and outcomes.
Regulatory Reporting: When required by law or regulations, we report confirmed violations to the appropriate authorities and cooperate fully with any investigations or legal proceedings.

Continuous Improvement:

Feedback and Evaluation: We actively seek feedback from stakeholders and assess the effectiveness of our investigation and remediation processes. This feedback drives ongoing improvements in our policies and practices.

Through our robust investigation and remediation processes, we demonstrate our unwavering commitment to ethical sourcing and modern slavery prevention. We believe that prompt and effective action is essential to address violations, protect individuals, and continuously improve our ethical sourcing standards and practices.

Transparency and Communication

We prioritize transparency and open communication as cornerstones of our commitment to ethical sourcing and the prevention of modern slavery within Surgo. We believe that transparent practices and proactive communication are essential for building trust with our stakeholders and ensuring accountability.

Policy Accessibility:

Publicly Available Policy: We make our ethical sourcing and modern slavery policy easily accessible to the public, clients, workers, suppliers, contractors, and employees through our official website and other relevant channels.

Internal Communication:

Employee Awareness: We actively communicate our ethical sourcing and modern slavery policy to all employees, ensuring that they are aware of its existence, importance, and objectives. Employees are encouraged to report concerns related to policy compliance.
Training and Education: We provide regular training and educational programs to our employees to enhance their understanding of ethical sourcing principles and modern slavery prevention.

Stakeholder Engagement:

Supplier and Contractor Engagement: We engage with our suppliers and contractors to communicate our ethical sourcing expectations and requirements, fostering a culture of compliance and accountability.
Employee Awareness: We offer resources and communication materials to inform workers about their rights, protections, and the reporting mechanisms available to them under our policy.

Reporting Mechanisms:

Accessible Reporting Channels: We maintain clear and accessible reporting mechanisms that allow stakeholders to report concerns, potential violations, or incidents related to modern slavery or unethical sourcing practices.
Confidential Reporting: We ensure that stakeholders can report concerns confidentially and without fear of retaliation.

Transparency in Reporting:

Disclosure of Progress: We regularly disclose our progress in implementing the ethical sourcing and modern slavery policy, including updates on compliance, investigations, and remediation efforts.
Disclosure to Regulatory Authorities: When required by law or regulations, we disclose relevant information to the appropriate regulatory authorities, cooperating fully with investigations or legal proceedings.

Continuous Improvement:

Feedback and Collaboration: We actively seek feedback from stakeholders to identify areas for improvement in our policies, practices, and communication. We collaborate with stakeholders to implement necessary enhancements.

Through our commitment to transparency and communication, we aim to foster trust, collaboration, and accountability among all individuals and entities associated with our organisation. We believe that open and honest communication is vital for the cause of our ethical sourcing and modern slavery prevention efforts, ultimately leading to a more ethical and responsible ecosystem.

Continuous Improvement

We are dedicated to the ongoing enhancement of our ethical sourcing and modern slavery prevention efforts within our organisation. We understand that achieving and maintaining the highest ethical standards is a dynamic process that requires continuous improvement and adaptability.

Feedback and Evaluation:

Stakeholder Feedback: We actively seek feedback from stakeholders, including workers, employees, suppliers, contractors, and clients, to gauge their experiences, insights, and suggestions related to ethical sourcing and modern slavery prevention.
Regular Assessment: We regularly assess the effectiveness of our policies, procedures, and controls to identify areas for improvement and adaptation.

Collaboration and Learning:

Collaborative Efforts: We collaborate with stakeholders, including industry peers, civil society organizations, and regulatory bodies, to share knowledge, best practices, and experiences related to ethical sourcing and modern slavery prevention.
Education and Training: We invest in ongoing education and training programs to keep our workforce informed about the latest developments in ethical sourcing and modern slavery prevention.

Remediation and Corrective Action:

Response to Issues: When issues, concerns, or violations arise, we take them as opportunities for improvement. We conduct thorough investigations and implement corrective actions to prevent similar issues from occurring in the future.
Root Cause Analysis: We perform root cause analyses to understand the underlying factors contributing to issues and take comprehensive steps to address those root causes.

Regular Review and Updates:

Policy Review: We conduct regular reviews of our ethical sourcing and modern slavery policy to ensure its relevance and alignment with emerging best practices and evolving regulatory requirements.
Policy Updates: As necessary, we make updates to our policy, incorporating lessons learned, changes in laws or regulations, and industry advancements.

Benchmarking:

Performance Benchmarking: We benchmark our ethical sourcing and modern slavery prevention performance against industry standards, benchmarks, and key performance indicators to identify areas where we can improve.

Transparency in Reporting:

Disclosure of Progress: We transparently communicate our progress in implementing our ethical sourcing and modern slavery policy, sharing information about compliance, investigations, and remediation efforts.

Through our commitment to continuous improvement, we aim to adapt, grow, and evolve in our efforts to promote ethical conduct, prevent modern slavery, and protect human rights within our organisation. We believe that by continuously striving for better practices, we can create a more responsible and ethical working environment.

Third-Party Verification

We are deeply committed to maintaining the highest standards of ethical conduct and the prevention of modern slavery within Surgo. While we primarily conduct verification processes in-house, we recognize the value of independent assessments when needed and commit to engage third-party verifiers in specific cases.

In-House Verification:

Internal Expertise: We have a dedicated team of internal experts responsible for conducting in-house verifications and assessments related to our ethical sourcing and modern slavery prevention efforts.
Regular Assessments: Our in-house verification team performs regular and comprehensive assessments to evaluate compliance with our ethical sourcing and modern slavery policy.

Third-Party Engagement:

Specific Cases: While we primarily rely on in-house verification, we recognize that there may be situations where third-party verification is beneficial or required. In such cases, we will engage third-party verifiers who are qualified and experienced in ethical sourcing and modern slavery prevention assessments.
Impartiality and Independence: Third-party verifiers engaged in specific cases will operate impartially and independently, ensuring that they are free from conflicts of interest that could compromise their objectivity.

Scope of Verification:

Determination of Need: The decision to engage third-party verifiers in specific cases will be based on the determination of need, considering factors such as the complexity of the verification, the scale of operations, or regulatory requirements.
Scope Definition: The scope of verification conducted by third-party verifiers will be clearly defined and communicated, ensuring a focused and relevant assessment.

Compliance Assessment:

Verification Objectives: Third-party verifiers engaged in specific cases will assess our compliance with the ethical sourcing and modern slavery policy, focusing on the areas identified as requiring independent verification.

Reporting and Findings:

Independent Reporting: Third-party verifiers will produce independent reports that include their findings, assessment results, identified strengths, areas for improvement, and recommendations.
Disclosure: These independent verification reports will be made available to stakeholders, enhancing transparency and accountability when third-party verification is conducted.

Corrective Action and Remediation:

Response to Findings: When third-party verifications reveal non-compliance or areas of improvement, we will take prompt corrective action and remediation steps to address the identified issues.

Through this approach, we aim to maintain transparency and accountability while primarily relying on our in-house verification capabilities. We believe that our internal expertise, combined with the selective engagement of third-party verifiers in specific cases, ensures the effectiveness of our ethical and modern slavery prevention efforts within Surgo.

Anti-Human Trafficking

At Surgo, we are unwavering in our commitment to ethical sourcing and human rights. We vehemently oppose any form of human trafficking and modern slavery within our supply chain and operations. We recognize that human trafficking is a grave violation of fundamental human rights, and we actively work to eliminate any associated risks within our global business network. To achieve this, we engage in rigorous due diligence processes, collaborating with suppliers, partners, and relevant stakeholders to ensure that our supply chain is free from any involvement in human trafficking. We continuously educate our employees, suppliers, and partners about the signs of human trafficking and provide mechanisms for reporting any concerns. Through these measures, we aim to create a culture of vigilance and responsibility, contributing to the global efforts to eradicate human trafficking and uphold the dignity and rights of all individuals.

Local Context Sensitivity

We recognize the importance of adapting our ethical sourcing and modern slavery prevention efforts to the unique local context and challenges. While maintaining global ethical standards, we understand the need for nuanced approaches that consider the specific socio-economic, cultural, and legal factors in South Africa.

Compliance with Local Laws:

Legal Adherence: We commit to strict adherence to all South African laws and regulations pertaining to ethical sourcing, labour, and human rights. Our policies and practices will align with and respect local legal requirements.
Engagement with Authorities: We maintain open communication and cooperation with relevant local authorities and regulatory bodies to ensure compliance with local laws and to address any emerging issues.

Cultural Sensitivity:

Cultural Awareness: We promote cultural sensitivity within our operations, respecting local customs, traditions, and values while upholding our global ethical standards.

Community Engagement:

Supporting Local Communities: We actively seek ways to contribute positively to local communities within South African jurisdiction, aiming to create opportunities for economic empowerment and development.
Community Feedback: We value feedback from local communities and incorporate their insights into our ethical sourcing and modern slavery prevention strategies.

Stakeholder Engagement:

Local Stakeholder Collaboration: We actively engage with local stakeholders, including workers, employees, suppliers, and contractors, to address their specific concerns and needs related to ethical sourcing and modern slavery prevention.

Through our commitment to local context sensitivity, we aim to strike a balance between global ethical standards and the unique circumstances within South African jurisdiction. By understanding and respecting the local context, we believe we can better address modern slavery risks, promote ethical conduct, and protect human rights, fostering a more responsible and sustainable organisation.

Review and Revision

We are committed to the ongoing improvement and adaptability of our ethical sourcing and modern slavery policy within Surgo. To ensure the continued effectiveness and relevance of our policy, we establish a systematic process for regular review and revision.

Periodic Policy Review:

Regular Assessment: Our ethical sourcing and modern slavery policy will undergo periodic reviews to evaluate its alignment with our objectives, evolving best practices, and regulatory changes.
Review Frequency: The policy will be reviewed at least once a year or more frequently as deemed necessary by our responsible team.

Stakeholder Engagement:

Consultation: We actively seek input and feedback from key stakeholders during the policy review process.
Feedback Incorporation: Insights and recommendations gathered from stakeholders will be considered during the revision process.

Regulatory Compliance:

Legal Updates: We will ensure that our policy reflects any changes in South African laws and regulations related to ethical sourcing, labour, and modern slavery prevention.
Prompt Adaptation: Any required adaptations to the policy based on regulatory changes will be implemented promptly to maintain compliance.

Continuous Improvement:

Lessons Learned: We use insights gained from internal and external assessments, investigations, and verification processes to identify areas for improvement in our policy.
Implementation of Best Practices: We actively seek opportunities to incorporate emerging best practices in ethical sourcing and modern slavery prevention into our policy.

Transparent Communication:

Disclosure: We maintain transparency by communicating updates, revisions, and changes to our ethical sourcing and modern slavery policy to all relevant stakeholders.
Accessibility: The updated policy will be easily accessible to all stakeholders through our official website and other relevant communication channels.

Approval Process:

Policy Approval: Any revisions to the ethical sourcing and modern slavery policy will undergo an internal approval process involving key stakeholders and senior management.

Effective Date:

Commencement of Revisions: The revised policy will specify its effective date, ensuring that all stakeholders are aware of the date from which the changes take effect.

Through this review and revision process, we aim to uphold the highest standards of ethical conduct and modern slavery prevention, continually improving our efforts to protect human rights and promote ethical sourcing practices within Surgo. We remain dedicated to adapting and strengthening our policy to meet the evolving challenges and responsibilities of our industry.

Risk Management

All risks identified and associated with this policy/procedure are recorded on the Risk Management Register(Risk Management.loop) and managed according to the Risk Management Policy.

Corrective Action

The company’s Corrective Action Procedure (SUR-ALD-PRO006-Corrective Action Process) will be activated if this policy fails to meet the objectives.

Updating, Distribution and Communication of this Document

This policy can be updated by the Process Owner following the procedure defined in the Document and Control of Records Process.

The distribution of this process document is circulated to the following persons:

Director
Other Company Directors
Information Security Management Officer
Risk and Compliance

Management Review

Management should review this document on a continual improvement basis for suitability, adequacy, and effectiveness, at least no less than every twelve months.

Reports required for the reviewing of input and output of this process are:

Customer service delivery reports
Minutes of Customer Meetings
Follow-up actions from previous management reviews
Risk Registers
Information Security Incident Management Reports

The output from the Management Review will include:

Improvements of the effectiveness of the Information Security Management System and its processes
Resources needed.
Improvements of the process related to provision of service to the business.
Updates to Information Security Plans
Updates to the Information Security Risk Register