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Anti Trafficking Statement

(Modern Slavery Act 2015)

Statement Summary

Modern slavery encompasses slavery, forced and compulsory labour, and human trafficking, whereby individuals are deprived of their freedom and are exploited for commercial or personal gain as defined in the Modern Slavery Act 2015. All forms of modern slavery have in common the deprivation of a person’s liberty by another to exploit them for commercial or personal gain, and amount to a violation of an individual’s fundamental human rights.

Techint Labs is committed to combating and preventing slavery and human trafficking, and to acting with integrity in all our dealings, relationships, and supply chains.

Techint Labs expects the same high standards from all our staff, suppliers, contractors, and those with whom we do business. The aim of this statement is to highlight and confirm the key procedures and measures that Techint Labs has put in place to ensure that the use and support of slavery and human trafficking within the Techint Labs supply chain and the Techint Labs organization is strictly prohibited.

Although we are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015, we are making this voluntary statement to show our commitment to ethical trading principles and as above, to set out the steps we are taking to identify risks and tackle modern slavery and human trafficking in our business and in our supply chains.

The Modern Slavery Act 2015 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 to exploit them

Other forms of modern slavery, which will not be tolerated by Techint Labs but are not specifically referenced in the Modern Slavery Act of 2015, include, but are not limited to, Child Labor: While not always illegal in the jurisdiction in which it takes place, child labor 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 well-being, or social development.

About Techint Labs

At Techint Labs, we believe in pushing boundaries, embracing challenges, and evolving constantly to meet the dynamic needs of our clients and partners. Through cutting-edge technology and innovative strategies, we stay ahead of the curve, delivering impactful solutions that drive our clients’ businesses forward. with its head office in Denver, United States.

AWithin the context of this statement, “Supplier” shall refer to any vendor, software, supplier, or external organization with which Techint Labs has a business relationship.

Techint Labs has a number of policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business, each of which is continually reviewed and updated.

Our Anti-trafficking Policy reflects our commitment 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 are not taking place anywhere in our supply chains.

Due Diligence: Prevention and Monitoring Measures

Techint Labs has mechanisms to combat and prevent slavery and human trafficking in line with this statement. The primary goal of these mechanisms is to prevent onboarding any supplier who is unable to meet the requirements of the Anti-trafficking Policy and, secondarily, to monitor active suppliers to validate that they maintain compliance during the relationship with Techint Labs. These mechanisms include:

Vendor Management Program

  • Onboarding – Prior to working with a new supplier, Techint Labs validates that they comply with the Modern Slavery Act of 2015. Failure to comply will result in the supplier being removed from consideration. The vendor may be provided an opportunity to
    address any shortcomings (e.g., develop and publish a policy) within an agreed-upon timeline that resolves the deficiency to Techint Labs’s satisfaction.
  • Annual Review – Techint Labs’s Vendor Management Program annually validates that suppliers are meeting their contractual, compliance, and service obligations. The vendor may be provided an opportunity to address any shortcomings (e.g., develop and publish a policy) within an agreed-upon timeline that resolves the deficiency to Techint Labs’s
    satisfaction.

Risk Program

The Techint Labs Risk Registry includes risks associated with suppliers not being compliant with the Modern Slavery Act at any point during their relationship with Techint Labs. The Risk Management policy includes a Treatment Plan for any risks that exceed the acceptable threshold. The Risk Registry is part of the quarterly Security & Compliance Steering Committee meeting agenda so risks are reviewed continually throughout the year.

Employee Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, employees are trained upon hire and annually thereafter on Techint Labs’ policies, which include the Anti-Trafficking Policy (Modern Slavery Act 2015). We also encourage our business partners to provide training to their staff and suppliers, and providers.

Reporting of Violations

As with any policy that is not being properly followed, or if you have questions about this policy, you may contact us at

(800) 949-3326, [email protected]

or:

Attn: Legal Counsel/Privacy 

865 Albion St Suite 400 

Denver, CO 80220

Contractual Agreements

We have zero tolerance for slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our ethics, we have in place a rigorous supply chain compliance program (as specified above), and to further ensure compliance, Techint Labs includes language that supports the objectives of this statement within our supplier contracts, including the incorporation of:

  • Specific prohibitions against slavery or servitude, the use of forced, compulsory, or trafficked labour, and the use of child labor in line with this statement and our Anti-trafficking Policy.
  • Provision for our contracted suppliers to hold their own suppliers to the same standards. We also reserve the right to terminate any contractual arrangement if there is a breach of this statement and our Anti-trafficking Policy.

Reporting

Techint Labs reports on the status of compliance with the Modern Slavery Act 2015 on an annual basis (beginning Q2 2026, 12 months after implementation). The reporting will be done by GRC and shall include:

Violations of this policy by Suppliers, Employees, and anyone else covered by the Anti-trafficking Policy.

  • Status of Contractual Agreements with provisions related to the Anti-trafficking Policy.
  • Risk Registry score and any associated remediation actions
  • Any third-party review of this policy and the effectiveness of associated controls, if performed within the reporting period.
  • Suppliers denied
    onboarding for non-compliance, assisted to become/remain compliant, and those removed for non-compliance

Effectiveness

  • Target 100% Training of Employees
  • Pre-onboarding and annually thereafter, the Techint Labs Vendor Program requires vendors to meet this and other regulatory standards as applicable to Techint Labs.
  • Techint Labs is audited by external third parties annually

Financial Year 2024/25

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Techint Labs Group’s slavery and human trafficking statement for the financial year ending 2025/2026. It was approved by the board in June 2025.