Modern Slavery Statement

Commitment to Eradicating Modern Slavery

Modern slavery, including slavery, servitude, forced labour, and human trafficking, is a crime and a gross violation of human rights. Privasee upholds a zero-tolerance policy against all forms of modern slavery and is committed to ethical business practices in alignment with the Modern Slavery Act 2015. We ensure transparency in our operations and supply chains and strive to prevent any form of exploitation or coercion.

This policy applies to all persons working for or on behalf of Privasee in any capacity, including employees, contractors, suppliers, volunteers, interns, and business partners.

Supply Chain and Risk Assessment

Due to the nature of our business, we consider the risk of modern slavery to be low. Our supply chains involve procuring SaaS services from well-established US and UK technology companies. However, we remain vigilant and enforce stringent controls to ensure that all supply chain partners align with our values.

Supplier Standards

• Suppliers must explicitly prohibit forced, compulsory, or trafficked labor and commit to ethical business practices.
• We expect suppliers to uphold these standards within their own supply chains.

Key Principles and Practices

Privasee's commitment to eradicating modern slavery is implemented through the following:

Ethical Standards

• Zero-Tolerance Approach: Privasee prohibits engaging with any entity that participates in or supports modern slavery or human trafficking.
• Transparency: Our business operations and supply chain activities are reviewed to ensure compliance with ethical and legal standards.

Training and Awareness

• Annual training is provided to all employees on the risks of modern slavery and human trafficking.
• Specialized training is given to staff involved in procurement to ensure adherence to modern slavery procurement guidance.

Proactive Reporting and Accountability

• Employees are encouraged to report concerns or suspected breaches in accordance with our Whistleblowing Policy.
• We investigate all reports thoroughly and take corrective action when necessary.

Embedding the Policy

We integrate our principles into everyday operations by:

• Providing comprehensive induction training and ongoing education about modern slavery.
• Communicating our zero-tolerance stance to all suppliers, contractors, and business partners at the outset of relationships.
• Regularly reviewing internal processes and supplier practices to ensure compliance.

Governance and Responsibilities

• Overall Responsibility: Alex Franch Tapia, Privasee's CEO, is accountable for implementing and overseeing this policy.
• Daily Oversight: Management at all levels is responsible for ensuring compliance within their teams.
• Open Feedback: Employees and stakeholders are encouraged to provide feedback or suggestions to improve this policy.

Compliance and Breaches

Compliance with this policy is mandatory for all employees and business partners. Non- compliance will result in:

• Employees: Disciplinary actions, up to and including dismissal for gross misconduct.
• Suppliers or Partners: Termination of the business relationship.

We are committed to protecting whistleblowers from any detrimental treatment, including threats, dismissal, or disciplinary actions, for raising concerns in good faith.

Communication and Continuous Improvement

• This policy is communicated to all employees, suppliers, and contractors during onboarding and reinforced through regular updates.
• Privasee remains committed to continuously improving its systems and practices to combat modern slavery effectively.