Modern Slavery and Human Trafficking Policy

Purpose

Vanyar is committed to conducting business with integrity and respect for human rights. We do not tolerate modern slavery, human trafficking, forced labour, servitude, debt bondage, deceptive recruitment, child labour, or any practice that deprives people of their freedom.

Scope

This policy applies to Vanyar, our people, contractors, suppliers, and business partners. It covers our own operations and the suppliers we engage to help deliver our website, professional services, business operations, and client work.

Our business and supply chain

Vanyar is an independent Palantir Foundry and AIP specialist firm operating across markets including Singapore, Australia, and the United Arab Emirates.

As a professional services and technology business, our direct modern slavery risk is lower than in sectors such as manufacturing, construction, or agriculture. However, risk can still arise through outsourced services, contractors, recruitment, travel, events, office services, hardware, merchandise, cloud infrastructure, and the extended supply chains of our suppliers.

Our commitments

Vanyar will:

• comply with applicable labour, employment, and modern slavery laws;
• not use forced, bonded, trafficked, or child labour;
• expect workers to be employed freely, treated fairly, and paid in accordance with applicable law;
• avoid suppliers that knowingly engage in exploitative labour practices;
• assess modern slavery risk proportionately as our business and supplier base grows;
• investigate concerns raised in good faith and take appropriate action.

Supplier expectations

We expect suppliers and business partners to:

Where supplier risk is higher, Vanyar may request further information, include modern slavery clauses in contracts, seek written confirmations, or discontinue a supplier relationship if concerns are not addressed.

• comply with applicable laws and employment standards;
• prohibit slavery, forced labour, human trafficking, and the worst forms of child labour;
• ensure workers are not charged improper recruitment fees or required to surrender identity documents as a condition of work;
• provide safe working conditions, lawful wages, and reasonable working hours;
• apply similar expectations to their own subcontractors and suppliers where relevant.

Due diligence and risk management

Vanyar takes a risk-based approach. This may include reviewing supplier location, service type, labour intensity, use of subcontractors, recruitment practices, and any known human rights concerns.

If we identify a potential issue, we will prioritise the safety and interests of affected people, seek appropriate advice where needed, and work toward remediation before considering termination where that is the better outcome for workers.

Training and awareness

People involved in supplier selection, hiring, or contractor management will be made aware of this policy and the indicators of modern slavery risk.

Reporting concerns

Anyone who has a concern about modern slavery or human trafficking connected to Vanyar, our suppliers, or our services can contact us at hi@vanyar.com with the subject line "Modern slavery concern".

Vanyar will not tolerate retaliation against anyone who raises a concern in good faith.

Governance and review

Vanyar leadership is responsible for this policy. We will review it at least annually, or sooner if our operations, supplier base, or legal obligations materially change.

This policy is not intended to be a statutory modern slavery statement unless expressly stated. If Vanyar becomes subject to a statutory reporting regime, we will publish the required statement in accordance with applicable law.