Slavery and Human Trafficking Policy

Pursuant to Section 54 of the UK Modern Slavery Act 2015, ST Engineering iDirect Inc. dba iDirect and its affiliates (“iDirect,” “we,” “us,” “our” or the “company”) publish this Slavery and Human Trafficking Policy on its corporate website for the financial year ending 31 December 2021.

Introduction

iDirect opposes slavery and human trafficking in all its forms and is committed to ensuring there is transparency in our business. We have a zero-tolerance approach to modern slavery and we are committed to the highest standards of professionalism, integrity and ethical behavior in all our business dealings and relationships around the world.

In the last financial year, we have addressed modern slavery in our supply chains, by including language in our vendor/suppliers contracts ensuring vendors and suppliers are complying with the UK Modern Slavery Act 2015. We intend to further review our procurement processes and Procurement Policy. When onboarding vendors/suppliers we will be revising our Supplier Questionnaire to include questions assuring us that human trafficking and slavery do not exist in our vendors/supplier’s operations or supply chain. This year, we have implemented and published our Supplier Code of Conduct on our corporate website. We intend to continue to work in this area to comply with the Modern Slavery Act and to underscore the values and principles we seek to maintain.

Organizational Structure

For further information about ST Engineering iDirect, Inc dba please visit our website: https://www.idirect.net/st-engineering/.

iDirect is a global leader in IP-based satellite communications, which predominantly employs highly skilled and professionally qualified people. We consider the risk and exposure to modern slavery within our business to be low. Nonetheless, we have taken steps to ensure that such practices do not take place in our business. iDirect employees have access to our Whistleblowing Hotline, telephone numbers and mailing address in order to report any malpractice, impropriety, statutory-noncompliance or any wrong doing by board members, employees or suppliers in the course of their work. Our Human Resources Manual also guides employees on how to report any inconsistencies with iDirect’s ethical standards. We are determined to foster and maintain an environment where all parties can report any wrong doing, in good faith, without the fear of retaliation.

Training

Training on this policy will be completed no later than December 31, 2021. We will provide further training on modern slavery as appropriate.

Board Approval

This Policy has been approved by the iDirect Board of Directors.

 


Kevin Steen, CEO

For and on behalf of the members of ST Engineering iDirect, Inc. dba iDirect and its affiliates