I. Introduction

As a company specializing in the medical device field, SUNTOP has always conducted its business in accordance with the highest ethical and moral standards. We deeply recognize that modern slavery, including but not limited to slavery, servitude, forced labor, and human trafficking, seriously violates basic human rights and is a blatant of social justice and human dignity. This statement aims to elaborate on the measures taken by SUNTOP to ensure the elimination of modern slavery in its business and supply chain, risk management strategies, and future improvement directions.

 

II. Scope of Application

This statement applies to all employees, management personnel, and directors within SUNTOP, as well as external contractors, suppliers, and other partners who conduct business on behalf of the company. Whether directly involved in the company's operations or at various stages of the supply chain, all relevant parties must comply with the regulations regarding anti - modern slavery stipulated in this statement.

 

III. Company Policies and Commitments

1. Zero - Tolerance Policy: SUNTOP firmly adopts a zero - tolerance attitude towards modern slavery. We are committed to not participating in, tolerating, or supporting any form of modern slavery in all business activities and the supply chain of the company. Once any existence or potential existence of modern slavery issues is detected, the company will immediately take decisive measures for investigation and handling.

2. Ethical and Integrity - Based Operations: The company upholds the concept of ethical and integrity - based operations and regards anti - modern slavery as an important part of corporate social responsibility. We firmly believe that only through legal, fair, and humane business practices can the company achieve sustainable development and make positive contributions to society.

3. Supply Chain Management Commitment: We require all suppliers to also abide by strict ethical and legal standards to ensure that there is no modern slavery in their business activities and their own supply chains. When establishing cooperative relationships with suppliers, anti - modern slavery clauses will be incorporated into the contract agreements to clearly define the responsibilities and obligations of both parties in this regard.

 

IV. Risk Assessment and Management

1. Supply Chain Risk Assessment: Conduct comprehensive risk assessments of the supply chain on a regular basis to identify the links and regions where modern slavery risks may exist. Focus on key stages such as raw material procurement, manufacturing, and logistics transportation, as well as suppliers from high - risk regions or industries. By collecting industry data, research reports, and collaborating with professional institutions, we can gain an in - depth understanding of the modern slavery risk situation in different regions and industries.

2. Risk Grading and Response: According to the results of the risk assessment, manage the identified risks in a graded manner. For high - risk areas, develop special response measures and strengthen the frequency of supervision and review; for medium and low - risk areas, continue to monitor and regularly assess changes in risk levels. At the same time, establish a risk early - warning mechanism to enable timely action when risks change or abnormal situations occur.

 

V. Supplier Management

1. Supplier Screening: When selecting suppliers, anti - modern slavery standards are taken as important considerations. Potential suppliers are required to provide relevant supporting documents, such as social responsibility reports, labor compliance certifications, etc., to prove their measures and effectiveness in preventing modern slavery. Suppliers that cannot provide sufficient evidence or have a poor record will not be considered for cooperation.

2. Supplier Code of Conduct: Communicate SUNTOP's anti - modern slavery stance and requirements to all suppliers and require them to comply with the Supplier Code of Conduct formulated by the company. The code clearly stipulates that suppliers shall not use forced labor or child labor and must provide a safe and healthy working environment, reasonable working hours, and compensation. Suppliers are required to sign a commitment letter indicating their understanding and compliance with these guidelines.

3. Supplier Audits: Conduct regular on - site audits or document reviews of suppliers to ensure that they effectively fulfill their anti - modern slavery commitments. Audit contents include on - site inspections of workplaces, employee interviews, document reviews, etc., to verify whether suppliers have violated the code of conduct. For problems found during the audit, suppliers are required to immediately develop a rectification plan, and the implementation of the rectification will be tracked. If a supplier violates the rules repeatedly or refuses to rectify, the cooperation relationship will be terminated.

 

VI. Employee Training and Awareness Enhancement

1. Internal Training: Carry out regular employee training to improve employees' awareness and understanding of modern slavery issues. Training content includes the definition, manifestations, legal requirements of modern slavery, and how to identify and report related risks in the workplace. Ensure that employees understand the company's anti - modern slavery policy and their own responsibilities in preventing modern slavery.

2. Awareness Promotion: Continuously promote the importance of anti - modern slavery and the company's relevant policy measures through internal publicity channels, such as company announcements, internal publications, and emails. Encourage employees to actively participate in anti - modern slavery actions and create a good atmosphere of full participation.

 

VII. Reporting Mechanism

1. Establishment of Reporting Channels: Set up dedicated reporting email addresses and hotlines to provide convenient reporting channels for employees, suppliers, and other stakeholders. Ensure the confidentiality and security of the reporting channels, and whistleblowers do not need to worry about retaliation.

2. Investigation and Handling: Conduct serious investigations and handling of all received reporting information. Establish a special investigation team responsible for verifying the reported content. According to the investigation results, corresponding corrective and preventive measures will be taken, including penalties for violations, improvement of systems and processes, etc., and the handling results will be timely feedback to the whistleblowers.

 

VIII. Future Outlook and Improvement Measures

1. Continuous Improvement: SUNTOP will continue to pay attention to the latest developments and best practices in the field of modern slavery and constantly improve the company's anti - modern slavery policies and measures. Regularly evaluate and summarize the company's anti - modern slavery work, analyze existing problems and deficiencies, and formulate targeted improvement plans.

2. Strengthened Cooperation: Actively cooperate with industry associations, non - governmental organizations, and other enterprises to jointly promote progress in anti - modern slavery within the medical device industry. By sharing experiences, exchanging information, and participating in industry initiatives, we can form a synergy to jointly address this global challenge.

3. Regular Reporting: In accordance with relevant laws, regulations, and industry standards, regularly publish the company's anti - modern slavery reports to publicly disclose the company's work progress and effectiveness in this regard to stakeholders. Accept social supervision and continuously enhance the company's transparency and credibility.

 

SUNTOP is well aware that combating modern slavery is a long - term and arduous task that requires the joint efforts of all employees, suppliers, and all sectors of society. We will unswervingly fulfill our commitments and continue to take effective measures to contribute our part to the complete elimination of modern slavery.