Modern slavery statement

This is a statement setting out the steps Security Monitoring Centres Limited and its subsidiaries (“SMC”) has taken during the financial year ending 31 DECEMBER 2021 (the “Reporting Period”) to ensure slavery and human trafficking is not taking place in any part of its own business or supply chain.

SMC monitors Fire & Security systems.

SMC is part of which provides API Group Corporation (“API”).

SMC is committed to ensuring slavery and human trafficking are not taking place in our business or supply chains and, to this end, took or continued to take the following actions during the Reporting Period.

API’s Code of Ethics
APIs Code of Ethics (the “Code”) is the foundation of our culture. The Code sets forth values and commitments that guide ethical decision making everywhere we do business. The Code applies to API and its controlled entities, worldwide. Among other things, the Code is adopted to encourage:

(i) honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships; (ii) fair dealing; (iii) the protection and proper use of Company assets; (iv) compliance with applicable governmental laws, rules and regulations; and (v) the reporting of any illegal or unethical behaviour.

Each year, SMC requires its employees to certify they have read and will comply with the Code. Compliance with the requirements of the Code is expected behaviour for all SMC employees. Violations of these requirements will result in appropriate corrective action.

SMC Anonymous Reporting Program
Employees who observe or suspect a violation of the Code may ask a question or raise concerns in complete confidence through SMC/API’s Anonymous Reporting Program.

Internal Training
SMC made and continues to make training available to company management and employees on recognising and mitigating the risk of human trafficking and slavery in supply chains. Employees with direct responsibility for supply chain management are assigned this training during their induction.

Supply Chain Expectations
To produce superior products in a responsible manner, we need suppliers who meet high standards for business practices, environmental responsibility and operational excellence. Accordingly, our suppliers are subjected to robust selection processes and criteria including verification against government denied party lists.

SMC’s standard contract terms and conditions of purchase require suppliers to comply with all applicable laws and regulations.

Further, SMC’s standard contract terms require suppliers to have management systems, tools and processes in place that (a) ensure compliance with applicable laws, regulations, (b) promote an awareness of and commitment to ethical business practices; (c) facilitate the timely discovery, investigation, disclosure and implementation of corrective actions for violations; and (d) provide training to employees on compliance requirements.

In the event a supplier commits any material violation of law relating to basic working conditions and human rights in their performance of work of their subcontracts with SMC, SMC has the right to terminate those subcontracts for default.

This statement has been approved by our Board of Directors on 10 March 2022.