Modern Slavery Act of 2015 Statement

Introduction

We, SP Internet, are committed to improving our practices to combat slavery and human trafficking in our business and supply chain. We are committed to ensuring there is no slavery or human trafficking in any part of our business and we will seek to ensure that our partners are equally committed to this cause.

Our Policy on Slavery and Human Trafficking

Scope

We have appropriate procedures and policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies.

We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Definitions

SP Internet recognizes the United Nations Global Compact’s (“UNGC”) Ten Principles which are based on The Universal Declaration of Human Rights. The UNGC specific Ten Principles are:

  • Support and respect the protection of internationally proclaimed human rights.
  • Ensure the company is not complicit in human rights abuses.
  • Uphold the freedom of association and the effective recognition of the right to collective bargaining.
  • Uphold the elimination of all forms of forced and compulsory labour.
  • Uphold the effective abolition of child labour.
  • Eliminate discrimination in employment and occupation.
  • Support a precautionary approach to environmental challenges.
  • Undertake initiatives to promote greater environmental responsibility.
  • Encourage the development and diffusion of environmentally friendly technologies.
  • Work against corruption in all its forms, including extortion and bribery.

Under the UNGC, Human rights are the same as labour rights; human trafficking and slavery assessments adopt UNGC assessment approach and definitions.

Supply Chain and Due Diligence

Supply Chain: Entities with which the enterprise has a direct or indirect business relationship and which either (a) supply products or services that contribute to the enterprise’s own products or services or (b) receive products or services from the enterprise.

Due Diligence: Due diligence in the context of human rights comprises an ongoing management process designed to support the organization in meeting its responsibility to human rights. A human rights due diligence process should include assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed.

Policy

While SP Internet, and its subsidiaries' services are sold globally, its supply chain and engagement with suppliers is extremely narrow. Nevertheless, SP Internet focuses its efforts to comply with these rules. We expect our suppliers not to be involved in forced, bonded (including debt bondage) or indentured labour, involuntary prison labour, slavery or trafficking of persons of any age at any tier of the supply chain. This includes transporting, harbouring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labour or services.

Organisation’s Structure

We are an internet technology company – focusing on creator platforms, gaming, procurement, and staffing services. We are the parent company for Comet Gaming, Ltd., Moonshot Services, Ltd. and SP Internet Media (Cyprus) Ltd. SP Internet, Ltd. has its head office in the Isle of Man. The group has over 50 staff members worldwide and operates out of the Isle of Man, United States, and Cyprus and provides its services to customers across the globe.

Our Business

Our business is organised into seven business units:

  • General & Executive Management
  • Finance
  • Human Resources
  • Marketing
  • Office of CTO
  • Legal
  • Product Management
Our Supply Chains

Our supply chain comprises a single point of production for online services (e.g., cloud-based online platforms with no tiering). AP Internet also conducts reviews of its vendors and suppliers through its vendor management process.

Due Diligence Processes for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk we have the following systems in place:

  • Identifying and assessing potential risk areas in our supply chains.
  • Mitigating the risk of slavery and human trafficking occurring in our supply chains.
  • Monitoring potential risk areas in our supply chains.
  • Maintaining a non-retaliatory mechanism for reporting any concerns related to this policy.
Supplier Adherence to Our Values

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme.

  • A Third Party Vendor Management Programme
  • Compliance with the Modern Slavery Act of 2015
  • Requiring our vendors certify their compliance with this Modern Slavery Statement
Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide mandatory Modern Slavery training to our staff.

This statement has been approved by the board on 01 January 2023 who will review and update it annually.