Sunseeker International Limited & Sunseeker International (Holdings) Limited - Slavery and Human Trafficking Statement for Financial Year 2024

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps Sunseeker International Limited and its parent company, Sunseeker International (Holdings) Limited (together Sunseeker), have taken since Sunseeker’s last statement to ensure that slavery and human trafficking do not take place within its business, business relationships or supply chains. This statement relates to Sunseeker’s 2024 financial year, which ended on 31 December 2024.

Sunseeker requires all its suppliers across the world to comply with the Sunseeker Code of Conduct for Suppliers (the Code) and to ensure compliance with the Code by all sub-suppliers and other third parties acting on their behalf. The Code can be accessed via Sunseeker’s Supplier Portal on its website and is incorporated into Sunseeker’s Standard Terms and Conditions for the Purchase of Goods and Services (Purchasing Terms) and Sunseeker’s Supply Agreements.

The Code requires all suppliers to adopt a zero-tolerance approach to slavery, servitude and the use of forced, compulsory or trafficked labour and to implement due diligence procedures for its sub-suppliers, subcontractors and other participants in its supply chains to ensure there is no slavery or human trafficking in its supply chains. Sunseeker reserves the right to terminate relationships with suppliers in the event of non-compliance.
In addition, our Supply Agreements and Purchasing Terms include express prohibitions on modern slavery practices within suppliers’ businesses and supply chains.

To ensure that Sunseeker’s worldwide distribution network is also free from modern slavery and human trafficking, the Company’s distribution agreements include provisions requiring each distributor to comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force (including the UK Modern Slavery Act 2015). Distributors and dealers are required to confirm annually that they are complying with all such anti-slavery and human trafficking legislation.

Since our last statement, we have built on last year’s revision of our Business Conduct Reporting Policy and the relaunch of our dedicated, 24-hour, confidential reporting service – operated by an independent third party – by introducing regular reminders in our weekly business updates to employees, contractors and consultants. The reminders restate Sunseeker’s commitment to ensuring that its supply chain and worldwide distribution network is free from modern slavery connected in any way with Sunseeker’s business.

The updates encourage all those working for Sunseeker to raise any concerns they may have about the possible use of modern slavery in any part of the supply, production or distribution chain and highlight the Business Conduct Reporting Policy and the existence of Sunseeker’s independent confidential reporting service to make it easier for all those working for Sunseeker to report damaging and/or unethical behaviours or practices.
This statement has been approved by Sunseeker’s Board of directors on 27 June 2025 and is signed on behalf of Sunseeker by its Chief Executive Officer.