ConnectByCode Modern Slavery and Human Trafficking Statement

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and sets out the steps ConnectByCode Ltd (“ConnectByCode”, “we”, “our”, or “us”) has taken and will continue to take to prevent modern slavery and human trafficking in our business and supply chains for the financial year ending [25-07-2025].

Our business

ConnectByCode is a software company focused on building and operating digital products and services, including SaaS platforms and custom solutions for clients. We operate from [location(s)] and serve customers globally. Our direct workforce consists primarily of employees and contractors in engineering, product, design, sales, and operations.

Our supply chains

Our supply chains are largely composed of:

• Cloud infrastructure, data centers, and managed services providers.

• Software licensing, development tools, and professional services.

• Office operations, equipment, and facilities services where applicable. While our risk is lower than sectors involving large-scale manufacturing or manual labor, we recognize that modern slavery risks can exist in technology supply chains (for example, in hardware manufacturing, subcontracted services, or outsourced labor).

Policies and governance

We maintain and are implementing the following policies to mitigate modern slavery risks:

• Code of Conduct and Supplier Code of Conduct prohibiting forced labor, human trafficking, child labor, and debt bondage.

• Ethical Sourcing and Human Rights Policy aligned with ILO core conventions and the UN Guiding Principles on Business and Human Rights.

• Whistleblowing/Speak-Up Policy enabling confidential reporting without retaliation.

• Recruitment and Right-to-Work checks to prevent hidden labor exploitation in our direct hiring and contracted roles.

• Diversity, Equity, and Inclusion commitments and expectations for respectful workplaces.

Responsibility for this program sits with [Chief Executive/Managing Director] and is overseen by the Board. Day-to-day ownership rests with [Head of Operations/Compliance].

Due diligence on suppliers and partners

We apply a risk-based due diligence approach when engaging or renewing suppliers:

• Screening for sanctions, adverse media, and human rights controversies.

• Contractual commitments to comply with the Modern Slavery Act and our Supplier Code, including audit rights and corrective action plans.

• Assessing geographic and product/service risk, with enhanced checks for higher‑risk categories (e.g., hardware, facilities, outsourced labor).

• Flow‑down of requirements to subcontractors engaged by our suppliers where relevant.

Risk assessment and management

We periodically assess risks across:

• Category risk (hardware and facilities services considered higher risk).

• Country risk (based on reputable indices such as ITUC, US State Dept., and modern slavery prevalence data).

• Supplier maturity (policies, governance, traceability). Where elevated risk is identified, we may require additional attestations, third‑party audits, remediation plans, or choose to disengage.

Training and awareness

• Mandatory training for staff involved in procurement, vendor management, HR, and facilities on identifying and escalating modern slavery concerns.

• Awareness materials for all employees on recognizing signs of exploitation and how to report concerns.

• Supplier onboarding includes acknowledgement of our standards and guidance on practical expectations.

Measuring effectiveness

We track and review:

• Percentage of in‑scope suppliers that have accepted our Supplier Code and modern slavery clauses.

• Completion rates for staff training in relevant teams.

• Number of supplier assessments completed and any corrective actions taken.

• Reports received through our Speak‑Up channels and outcomes.

• Annual review of our risk assessment and policy effectiveness.

Reporting concerns

If you believe someone connected to our business or supply chain is at risk of modern slavery or human trafficking:

• Employees and contractors should report via our Speak‑Up channel or to HR/Compliance.

• External parties can contact us at compliance@connectbycode.com. All reports are investigated promptly and handled sensitively. We do not tolerate retaliation against anyone who raises a concern in good faith.

Continuous improvement and next steps

Over the next year we plan to:

• Expand supplier risk mapping to deeper tiers in higher‑risk categories.

• Strengthen verification for hardware and facilities suppliers, including potential third‑party audits.

• Enhance training content with sector‑specific case studies and refreshed guidance.

• Publish updated KPIs and progress in our next statement.

Approval

This statement was approved by the Board of Directors of ConnectByCode Ltd on [25-07-2025]

For prior statements and updates, please visit www.connectbycode.com.