Santa Fe anti-modern slavery policy 2021

Introduction

This policy sets out Santa Fe Group’s actions to understand all potential modern slavery risks related
to its business and to put in place steps that are aimed at ensuring that there is no slavery or human
trafficking in its own business and its supply chains.

The Santa Fe headquarters are based in the UK and this policy applies to all Group companies
globally.

Santa Fe maintains relationships with many different organisations in its supply chain, as well as
directly employing a large number of people. In the light of the general law on employment and human
rights and more specifically, the Modern Slavery Act 2015, the Group is absolutely committed to
preventing slavery and human trafficking.

Our commitment to the principles of the Modern Slavery Act 2015

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as
slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common
the deprivation of a person’s liberty by another in order to exploit them for personal or commercial
gain. We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically
and with integrity in all our business dealings and relationships and to implement and enforce effective
systems and controls to ensure modern slavery is not taking place anywhere in our own business or
our supply chain.

About Santa Fe

Santa Fe is a global leader in international mobility, handling around 45,000 international and
domestic relocations annually, 52,000 international and domestic moves and 40,000 applications for
immigration. Santa Fe’s mission is to make it easy for people to work, live and thrive in new places
around the world.

Santa Fe provides a full range of mobility services for multinational companies and other organisations
having executives and professionals on overseas assignments. In addition to this, Santa Fe serves
individual customers relocating without the support of an employer. The service offering covers the
entire relocation journey– from immigration services to obtaining work and resident permits through
the physical packing–and moving of household goods to a comprehensive range of value-added
relocation and destination services to ensure the relocating individual or family settles into their new
home in the best possible way.

Santa Fe designs and manages entire relocation programmes for large organisations with
international operations. Our value proposition is to provide our corporate customers with optimum
efficiency in their mobility management, full compliance with all relevant legal regimes, and a safe and
easy transition and new start for the relocating individual and family.

Further information about our business can be found at www.santaferelo.com

Organisational structure

This policy covers all the activities of Santa Fe Group and its subsidiaries. It drives all our business
dealings and the conduct of all persons or organisations with whom we contract directly or who we
appoint to act on our behalf.

We expect all who have, or seek to have, a business relationship with Santa Fe and/or any member of
our Group, to familiarise themselves with our anti-slavery policy and to act at all times in a way which
is consistent with our anti-slavery policy.

Santa Fe Group expects its subsidiaries and all supply chain to adhere to recruitment practices that
ensure that all terms of employment are voluntary. Where necessary and if required, we may request
demonstration of compliance with this policy.

Supply chains

Due to the nature of our business and the relocation industry in general our supply chain extends
globally.

Our policy on modern slavery is communicated to all suppliers, contractors and business partners at
appropriate points during our business relationship with them and reinforced as appropriate thereafter.
Furthermore, adherence to our modern slavery policy and principles is a contractual obligation and
suppliers are not allowed to outsource to another supplier without explicit written consent.
Prior to engaging any third-party rigorous screening and background checks are undertaken using an
industry leading third-party service.

Of the services provided over 96% were deemed to be inherently low risk with the remainder being
initially classed as medium but, taking into consideration mitigating controls, the residual risk was
deemed as low.

Embedding principles

We continue to embed the principles through all employees undertaking the following awareness
training:

• Modern slavery
• Harassment and bullying
• Anti-Bribery and corruption
• Anti-Money laundering

We expect employees to understand, refer to and abide by the above policies.

The following policies are available to all staff via the Santa Fe intranet:

• Anti Modern Slavery
• Code of Business Conduct
• Integrity hotline
• FIDI Anti Bribery and corruption charter

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Key Performance Indicators

The following KPIs are used to measure how effective we have been to ensure that slavery and
human trafficking is not taking place in any part of our business or supply chain:

• The percentage of staff that have completed Anti Modern Slavery awareness training;
• The number of reported instances of modern slavery within our business operations and supply chain;
• The nature and number of calls to our Integrity Hotline relating to Modern slavery;
• Ensuring that all staff directly involved in the supply chain management receive ongoing updates and notifications regarding business and human rights and specifically modern slavery.

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This statement was approved and signed by Runar Nilsen, Deputy Chief Executive Officer, for the financial year ending 31st December, 2021.

Issue date: 23/11/2021

Owner: Legal and Compliance