Modern Slavery Act

At Strongbyte Solutions Limited and across our subsidiaries (the ‘Group’), it remains our priority to trade ethically, source responsibly, and actively prevent modern slavery and human trafficking within our organisation and across our supply chain. This statement highlights the key activities we have undertaken during this financial year to combat modern slavery in our organisation and supply chain. We are committed to improving our efforts to combat modern slavery and human trafficking in all aspects of our operations.

The principal activities of the Group are to develop an enterprise-wide team communication solution that enables retail colleagues to communicate instantly and effectively to resolve customer and staff queries. These products and software services enable deskless teams to communicate using wireless headset devices and simultaneously receive automated or user-generated messages. Our products and software services have been developed by the Group and deployed to some of the world’s leading retailers. The Group had around 150 employees at 31st December 2024, and operates primarily in the UK, DACH, and USA.

We have a zero tolerance policy with regards to slavery and human trafficking. To effectively assess and manage the risks of modern slavery, the Group has implemented comprehensive due diligence processes. These processes are designed to identify, prevent, and mitigate any potential risks within our operations and supply chains. Our risk assessment includes:

• Supplier Audits: Regular audits of our suppliers to ensure compliance with our ethical standards.
• Risk Mapping: Identifying high-risk areas within our supply chains and focusing our efforts on these areas.
• Stakeholder Engagement: Collaborating with stakeholders to gain insights and improve our risk management strategies.

Our due diligence processes are integral to our efforts to combat modern slavery. These processes include:

• Supplier Code of Ethics: All suppliers are required to adhere to our Supplier Code of Ethics, which explicitly prohibits any form of modern slavery and human trafficking.
• Contractual Obligations: We include specific clauses in our contracts with suppliers to ensure compliance with anti-slavery laws and standards.
• Monitoring and Reporting: Continuous monitoring of our supply chains and a robust reporting mechanism for any suspected cases of modern slavery.

The Group believes that education and awareness are key to preventing modern slavery. We provide regular training to our staff to ensure they understand the risks and indicators of modern slavery. Our training programs cover:

• Identification of Modern Slavery: Educating employees on how to identify signs of modern slavery.
• Reporting Mechanisms: Training staff on the procedures for reporting any concerns or suspicions.
• Ongoing Education: Regular updates and refresher courses to keep our staff informed of the latest developments and best practices.

The Group has established a comprehensive set of policies to support our commitment to preventing modern slavery. These include:

• Code of Conduct: Our Code of Conduct outlines our ethical standards and expectations for all employees and partners.
• Supplier Code of Ethics: A detailed code that sets forth the requirements for our suppliers regarding labour practices and human rights.
• Whistleblower Policy: A policy that encourages employees to report any unethical behaviour without fear of retaliation.

To ensure the effectiveness of our efforts, the Group employs several measures, including:

• Performance Indicators: Tracking key performance indicators related to modern slavery risks and incidents.
• Regular Reviews: Conducting regular reviews of our policies and procedures to identify areas for improvement.
• Feedback Mechanisms: Soliciting feedback from employees, suppliers, and partners to enhance our strategies.

The Group is dedicated to maintaining a transparent and ethical business environment. We will continue to evaluate and improve our practices to ensure that modern slavery and human trafficking have no place in our operations or supply chains. We are committed to working collaboratively with all stakeholders to achieve this goal.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 31st December 2024. It was approved by the board on 18th June 2025.