Modern Slavery and Human Trafficking Statement

1. Opening Statement from Senior Management

N90 Labs Limited is committed to preventing modern slavery and human trafficking in all its forms within our business and supply chains. We recognise that modern slavery is a serious crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

We are absolutely committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

2. Structure of the Organisation, Our Business and Supply Chains

N90 Labs Limited (Company No. 17006232) is a technology company registered in England and Wales, specialising in AI-native software engineering, security assessments, and technology consulting. We operate from London with a remote-first workforce model.

Our supply chain primarily consists of:

• Cloud infrastructure providers (Vercel, Supabase, AWS)
• Software-as-a-service platforms (Anthropic, Stripe, Resend, Slack, Google Workspace)
• Professional services contractors and consultants
• IT equipment suppliers
• Office and administrative service providers

Our workforce is based entirely in the United Kingdom. We do not operate in any high-risk jurisdictions and our supply chain is predominantly composed of established technology companies and professional service providers based in the UK, EU, and United States.

3. Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

• Anti-Bribery and Corruption Policy — We maintain a zero-tolerance approach to bribery and corruption in line with the Bribery Act 2010.
• Equality, Diversity and Inclusion Policy — We are committed to providing equal opportunities and preventing discrimination in all aspects of employment.
• Whistleblowing Policy — We encourage all employees, contractors, and suppliers to report concerns about any aspect of the organisation, including any suspicion of modern slavery, without fear of retaliation.
• Recruitment Policy — We verify the identity and right to work of all employees and contractors. We ensure fair terms of employment and pay at least the National Living Wage.
• Supplier Code of Conduct — We expect our suppliers to share our commitment to ethical business practices and to have their own policies in place to prevent modern slavery.

4. Due Diligence

As part of our initiative to identify and mitigate risk, we have put in place the following due diligence procedures:

• Conducting risk assessments of our supply chain, focusing on areas with higher inherent risk of modern slavery
• Verifying the identity and right to work status of all employees and contractors at the point of recruitment
• Reviewing the modern slavery statements and ethical policies of key suppliers
• Including anti-slavery provisions in our contracts with suppliers and service providers
• Maintaining a whistleblowing mechanism for reporting concerns confidentially

5. Risk Management

We assess the risk of modern slavery occurring within our business and supply chain on an ongoing basis. Given the nature of our business (technology consulting with a UK-based professional workforce and an established technology supply chain), we consider the overall risk to be low. However, we remain vigilant and continue to monitor for any indicators of modern slavery, particularly in relation to:

• New supplier relationships
• Use of sub-contractors or temporary workers
• Procurement of hardware or physical goods
• Any changes to our operational model that could introduce higher-risk elements

6. Effectiveness and Key Performance Indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

• No reports are received from employees, the public, or law enforcement to indicate that modern slavery practices have been identified
• All employees have completed modern slavery awareness training
• Key suppliers have confirmed their own anti-slavery commitments
• Our recruitment processes have been audited and verified as compliant

We use the following key performance indicators (KPIs) to measure our effectiveness:

• 100% of employees to have received modern slavery awareness training
• 100% of new suppliers to be assessed for modern slavery risk before onboarding
• Zero incidents of modern slavery identified in our business or supply chain
• Annual review of this statement and related policies

7. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to all staff. Our training covers:

• What modern slavery is and the various forms it can take
• How to identify potential indicators of modern slavery
• What initial steps should be taken if modern slavery is suspected
• How to escalate potential modern slavery cases via our reporting procedures
• What external help is available, including the Modern Slavery Helpline (08000 121 700)

8. Further Actions and Sign-Off

Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains, we intend to take the following further steps to combat slavery and human trafficking:

• Continue to review and enhance our due diligence processes for new and existing suppliers
• Conduct annual refresher training for all staff on modern slavery awareness
• Expand our supplier code of conduct to include more detailed anti-slavery provisions
• Publish an updated statement annually in accordance with the Modern Slavery Act 2015

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes N90 Labs Limited’s slavery and human trafficking statement for the financial year ending 2026.