1. Policy Purpose

SUNTOP, as a small medical device company, recognizes that modern slavery, encompassing forced labor, human trafficking, and other related exploitative practices, is a severe violation of human rights and a threat to ethical business conduct. This Anti - Slavery Policy is designed to ensure that SUNTOP upholds the highest standards of integrity, and takes proactive steps to prevent any form of modern slavery from occurring within our own operations and throughout our supply chain.

 

2. Scope of Application

This policy applies to all SUNTOP employees, from management to front - line staff, as well as to all external contractors, suppliers, and partners who engage in business activities on behalf of the company. Whether involved in the production of medical devices, procurement of raw materials, or any other business - related functions, all parties must adhere to this anti - slavery policy.

 

3. SUNTOP's Commitment

• Zero - Tolerance Stance: SUNTOP firmly adopts a zero - tolerance approach towards modern slavery. We are dedicated to ensuring that no aspect of our business contributes to or tolerates any form of modern slavery. Any suspicion or discovery of modern slavery - related activities will be addressed with immediate and decisive action.

• Compliance with Laws: We are committed to complying with all relevant local, national, and international laws and regulations related to anti - slavery. This includes adhering to labor laws that protect workers' rights, prohibit forced labor and child labor, and ensure fair working conditions.

• Transparency and Accountability: SUNTOP will strive for transparency in our anti - slavery efforts. We will be accountable for our actions and will communicate our anti - slavery initiatives and progress to our stakeholders, including employees, customers, and suppliers.

 

4. Risk Assessment and Management

• Supply Chain Risk Evaluation: Given our position in the medical device industry, we will regularly assess our supply chain for potential modern slavery risks. We will focus on evaluating suppliers based on factors such as their location, the nature of the goods or services they provide, and their labor practices. Suppliers from regions with weak labor law enforcement or industries with known labor exploitation risks will be subject to more rigorous scrutiny.

• Risk Mitigation Strategies: To mitigate identified risks, we will implement a series of measures. This includes setting clear expectations for suppliers regarding anti - slavery compliance, conducting periodic reviews of supplier operations (either through document - based audits or, when feasible, on - site visits), and providing support and resources to suppliers to help them improve their labor practices. In cases of non - compliance, we will work with suppliers to develop corrective action plans or, if necessary, terminate the business relationship.

 

5. Supplier Management

• Supplier Screening: Before entering into a business relationship, all potential suppliers will be screened for their compliance with anti - slavery standards. We will request that suppliers provide documentation and information demonstrating their commitment to ethical labor practices, such as compliance certificates, employee welfare reports, or statements of labor policies.

• Supplier Code of Conduct: SUNTOP will incorporate anti - slavery requirements into our Supplier Code of Conduct. Suppliers will be required to confirm that they do not use forced or child labor, that they provide fair wages and reasonable working hours, and that they respect the rights of their employees. This code will be a condition of our business relationship with suppliers.

• Supplier Monitoring: We will establish a system for ongoing monitoring of suppliers. This may involve periodic requests for updated information on labor practices, as well as responding promptly to any concerns or complaints raised about a supplier's compliance with our anti - slavery policy.

 

6. Employee Training and Awareness

• Training Programs: SUNTOP will conduct regular training sessions for all employees to raise awareness of modern slavery issues. The training will cover the definition and forms of modern slavery, how to identify potential signs of slavery in the supply chain or workplace, and the importance of reporting any suspicions. Employees will also be educated on their responsibilities under this anti - slavery policy.

• Internal Communication: We will use internal communication channels, such as company meetings, newsletters, and internal memos, to keep employees informed about our anti - slavery initiatives. Encouraging employees to actively participate in our efforts to combat modern slavery and to feel comfortable reporting any concerns is a key part of our internal communication strategy.

 

7. Reporting and Investigation

• Reporting Mechanism: SUNTOP will establish a confidential reporting mechanism for employees, suppliers, and other stakeholders to report any suspected cases of modern slavery. This can include a dedicated email address, a hotline, or an internal reporting form. All reports will be treated with the utmost confidentiality, and whistleblowers will be protected from any form of retaliation.

• Investigation Process: When a report is received, a prompt and thorough investigation will be launched. A team, consisting of relevant departments such as human resources and procurement, will be responsible for conducting the investigation. The investigation may involve gathering evidence, interviewing relevant parties, and, if necessary, seeking external expertise or collaborating with law enforcement agencies.

• Corrective Actions: Based on the investigation results, appropriate corrective actions will be taken. If modern slavery is confirmed, SUNTOP will take immediate steps to address the situation, which may include terminating the relationship with non - compliant suppliers, providing support to any affected individuals, and implementing measures to prevent similar incidents in the future.

 

8. Policy Review and Improvement

• Regular Reviews: This anti - slavery policy will be reviewed on a regular basis to ensure its continued effectiveness and relevance. Changes in laws, industry best practices, or emerging trends related to modern slavery will be considered during these reviews.

• Continuous Improvement: SUNTOP is committed to continuous improvement in our anti - slavery efforts. We will learn from our experiences, both successful and otherwise, and use this knowledge to enhance our policies, procedures, and practices to better combat modern slavery within our business and supply chain.

As a small medical device company, SUNTOP is working towards the Sustainable Development Goals (SDGs). Currently, our medical devices support SDG by improving healthcare access, and our production efforts align with SDG. We communicate progress internally through meetings, sharing energy - saving and ethical supply chain initiatives.

In the future, we plan to set specific SDG targets by 2028, adopt GRI standards for reporting, and publicly disclose our progress on the website.