Modern slavery is a heinous crime and a morally reprehensible act that deprives a persons liberty and dignity for another persons gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.

At Qnetix, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015. This policy covers the activities of Qnetix Ltd and we are committed to preventing slavery and human trafficking violations in our operations, our supply chain, and our solutions.

We have a zero-tolerance towards slavery and require our supply chain to comply with our values.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Modern slavery can take many forms. It is a complex and multi-faceted problem. The policy covers four key criminal activities: Slavery – where ownership is exercised over an individual, Servitude: involves the obligation to provide service imposed by coercion. Forced and compulsory labour – all work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty. Human trafficking – involves arranging or facilitating the travel of another with a view to exploiting them.

Other forms of modern slavery, which we will not tolerate, but are not specifically referenced in the policy include, but are not limited to: Child labour – whilst not always illegal in the jurisdiction in which it takes places, child labour involves the employment of children that is exploitative, or is likely to be hazardous to, or interfere with, a child’s education, health (including mental health), physical wellbeing or social development.

All forms of modern slavery have in common the deprivation of a person’s liberty by another in order to exploit them for commercial or personal gain and amount to a violation of an individual’s fundamental human rights. Tackling modern slavery requires us all to play a part and remain vigilant to the risk in all aspects of our business and business relationships.

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the suppliers reputation, respect for the law, compliance with health, safety and environmental standards, and references.

We have not been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adapted the following due diligence procedures:

• Put in place a policy on slavery and human trafficking.
• Given appropriate awareness training on the matter and its related impacts.
• Ensure that sourcing processes are under the control of trusted and competent staff members.
• Require that our key suppliers adopt our code of conduct which prohibits the use of forced or involuntary labour or have reviewed / consulted with key partners and suppliers to assess their own policies and controls.

Qnetix has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in our supply chain and we do not tolerate slavery and human trafficking in our supply chains. We encourage all our staff, clients and other business partners to report any concerns related to the direct activities, or the supply chains of Qnetix.

The board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations and that all those under our control comply with it. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

The Company Secretary will ensure that relevant staff receive adequate training on this policy and any supporting processes applicable to their role. In addition, staff will receive training on the broader issues of modern slavery so as to assist them in appreciating the extent of the problem of modern slavery and then identify individuals/areas of the business that may be at risk from practices of modern slavery.

Qnetix has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These include:

• How many suppliers have filled out our ethics questionnaire?
• How many suppliers have rolled out an awareness and training programme that is equivalent to ours?
• How many reports have been made by our employees that indicate their awareness of and sensitivity to ethical issues?
• What are the findings of our cross-functional Human Rights team, which reviews how we are addressing modern slavery and human trafficking?

The statement was last reviewed and approved by the board of directors on 06 August 2024