SpacetoCo Modern-Slavery Statement (United Kingdom)

SpacetoCo is committed to ensuring that slavery, servitude, forced labour, and human trafficking (collectively "modern slavery") do not exist in any part of our business operations or supply chain. This statement outlines the steps we have taken to ensure that modern slavery is not taking place in our business or our supply chain in accordance with the Modern Slavery Act 2015 (UK).

Scope of the Statement
This statement covers all entities of SpacetoCo operating within the United Kingdom, including our suppliers and service providers who are directly involved in providing goods or services. This includes the first-tier suppliers through to subcontractors within the UK and other regions we operate in (e.g., Australia, New Zealand). This policy applies to all parts of the company, and we expect our partners, contractors, and suppliers to abide by similar ethical standards.

Our Commitment to Combatting Modern Slavery
SpacetoCo recognises that modern slavery is a serious issue and that it can occur anywhere in the supply chain. We are committed to the elimination of modern slavery in all forms, including forced, bonded, and child labour. To that end, SpacetoCo:

1. Has a Zero-Tolerance Policy for Modern Slavery: We prohibit the use of modern slavery in any part of our business operations and supply chain.

2. Ensures Compliance with UK Modern Slavery Act 2015: SpacetoCo complies with all legislative requirements under the UK Modern Slavery Act 2015, and this statement reflects the steps taken by the company to ensure compliance.

Supply Chain & Risk Assessment
To assess the risks of modern slavery occurring in our supply chain, we conduct annual risk assessments focusing on:

• Supplier Geographies: Identifying regions that may be at higher risk of modern slavery practices (e.g., countries with weaker labour laws or higher reports of forced labour).

• Supplier Types: Focusing on industries with higher exposure to modern slavery risks such as construction, agriculture, and textiles.

• Third-Party Audits: We require all suppliers to undergo an ethical audit to identify any risks associated with modern slavery in their operations.

• Supply Chain Length and Transparency: SpacetoCo works with tier 1 and tier 2 suppliers, and we are committed to increasing transparency across all levels of our supply chain, ensuring that modern slavery does not occur in any segment of the supply chain.

Due Diligence & Policies
We take a proactive approach to ensure that modern slavery risks are identified and mitigated across our operations and supply chain, including:

1. Supplier Contracts & Clauses: All supplier contracts include clauses prohibiting the use of modern slavery, human trafficking, and forced labour.

2. Supplier Due Diligence: We require all suppliers to undergo a due diligence process, which includes:

   • A self-assessment questionnaire to evaluate their modern slavery practices.

   • Documented evidence of their policies on human rights, labour rights, and modern slavery.

   • A right to audit suppliers to verify their compliance with our modern slavery expectations.

3. Employee & Partner Training: All employees, particularly those in procurement or supplier relationship management, undergo annual training on modern slavery risks. This training is also extended to key contractors and suppliers, where necessary.

4. Remediation & Reporting: If a modern slavery issue is identified, we take immediate corrective action, including suspending or terminating the relationship with the non-compliant supplier and offering support to affected workers.

Effectiveness of the Anti-Slavery Policies
SpacetoCo measures the effectiveness of our anti-slavery policies by tracking the following key performance indicators (KPIs):

1. Number of Audits Conducted: We aim to audit 100% of new suppliers annually and 25% of existing suppliers.

2. Supplier Compliance: Our goal is to have at least 95% of our suppliers compliant with our modern slavery policy.

3. Training Completion: We monitor that 100% of staff involved in procurement and vendor management receive training on modern slavery.

4. Incident Reporting: We track the number of modern slavery incidents reported or discovered during audits and proactively follow up with remediation steps.

Governance & Accountability
The SpacetoCo Board of Directors is responsible for ensuring the effective implementation of this policy. The HR and Procurement Teams are accountable for monitoring and reporting on progress, conducting training, and ensuring compliance. An annual review of the policy and its effectiveness is conducted by the Board.

Public Availability & Transparency
This statement is publicly available on our website and will be reviewed and updated annually to ensure its effectiveness and compliance with the Modern Slavery Act 2015 (UK).