Declaration on combating modern slavery - SCANDIC DATA

Introduction

Respect for human rights is a central concern of the SCANDIC GROUP. As part of this alliance, SCANDIC DATA takes responsibility for an ethical and transparent supply chain in the area of data center and cloud services. We do not tolerate any form of modern slavery, forced labor, child labor or human trafficking. This statement explains our approach to preventing such practices and is updated annually.

The company

SCANDIC DATA is represented by:

SCANDIC ASSETS FZCO
Dubai Silicon Oasis DDP
Building A1/A2, Dubai - 342001
United Arab Emirates
Phone +97 14 3465-949
Mail Info@ScandicAssets.dev
represented by the:

SCANDIC TRUST GROUP LLC
IQ Business Center
Bolsunovska Street 13-15
Kyiv - 01014, Ukraine
Phone +38 09 71 880-110
Mail Info@ScandicTrust.com

Cooperation partner:
LEGIER Beteiligungs mbH
Kurfürstendamm 14
10719 Berlin
Federal Republic of Germany
Mail: Office@LegierGroup.com

SCANDIC ASSETS FZCO and LEGIER Beteiligungs mbH are non-operational service providers; operational activities are carried out by SCANDIC TRUST GROUP LLC carried out.

Overview library

– 1. our approach against modern slavery
– 2. supply chain and risk management
– 3. expectations of business partners
– 4. training and awareness-raising
– 5. whistleblowing and remediation processes
– 6. evaluation and continuous improvement

1. our approach against modern slavery

SCANDIC DATA is committed to respecting human rights and fair working conditions along the entire value chain. Our guiding principles - integrity, transparency and responsibility - require us to proactively prevent forced labor, bonded labor, human trafficking and other forms of modern slavery. We integrate the requirements of the UK Modern Slavery Act 2015, the German Supply Chain Duty of Care Act and other national and international legislation into our business processes. We expect our employees, suppliers and partners to have a zero-tolerance policy towards modern slavery.

2. supply chain and risk management

Our supply chain includes the procurement of IT hardware (servers, network technology, storage), energy supply (electricity from renewable sources, diesel generators for emergencies), facility services (security, cleaning, catering), software and maintenance services as well as transportation. We regularly identify and assess modern slavery risks, particularly in countries and sectors with an elevated risk profile. Our measures include

– Supplier Code of Conduct:
All suppliers must accept binding human rights and labor standards, including the prohibition of child and forced labor, the payment of fair wages, the guarantee of occupational safety and the protection of the environment.

– Contractual obligations: Contracts contain clauses on compliance with the Modern Slavery Act and the Supply Chain Act as well as audit rights. For suppliers in high-risk areas, we require additional evidence and certifications (e.g. SA8000, ISO 45001).

– Audits and inspections: We carry out risk-based audits or request independent certificates. In the event of deviations, we agree specific remedial measures and deadlines. Repeated violations lead to the exclusion of the supplier.

– Risk analyses: New suppliers and existing partners are assessed with regard to country and sector risks. We use publicly available indices (e.g. Global Slavery Index) and internal evaluation matrices. Where risks are identified, preventive and remedial measures are defined.

3. expectations of business partners

We only work with partners who share our values. Our business partners must ensure that there is no form of modern slavery in their supply chains and that they commit their own suppliers accordingly. We expect transparency with regard to the origin of components and materials, working conditions and environmental practices. Violations of these requirements will result in remedial action; in the event of serious or repeated violations, the collaboration will be terminated.

4. training and awareness-raising

Employees, particularly in the areas of purchasing, operations, facility management and human resources, receive training on recognizing the risk factors of modern slavery. Awareness-raising measures explain reporting channels, possible warning signs (e.g. excessive working hours, restricted freedom of movement, chain employment contracts) and the legal framework. Managers are trained in how to carry out inspections and audits and how to encourage suppliers to make improvements.

5. whistleblowing and remediation processes

SCANDIC DATA provides a confidential whistleblower channel. Employees, suppliers and external third parties can report human rights violations anonymously or by name. Each report is investigated according to a defined procedure, documented and - if necessary - remedied together with the partners concerned. Those affected receive protection from reprisals. The results of the investigations are included in our reports and serve to continuously improve our processes.

6. evaluation and continuous improvement

We regularly review our strategies. Findings from audits, supplier assessments, whistleblower reports and industry initiatives are incorporated into the improvement of our processes. Progress and challenges in the fight against modern slavery are documented in our annual ESG report. SCANDIC DATA engages with industry initiatives and NGOs to adopt best practices and continuously strengthen our commitment.