Anti-slavery and Human Trafficking Statement

As a multinational organisation, MacPaw understands that we need to lead by example in the way we do business. We recognise that modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain.

We aim to act fairly, ethically and openly in everything we do and are committed to practices to combat slavery and human trafficking in our supply chains and in any part of our business.

Macpaw Family Limited, is a company registered in England and Wales with company number 11596716. Together with the other constituent subsidiaries and group companies it trades as, and is part of, the MacPaw group of companies (hereinafter the “Group”).

We are proud to state that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain.

This statement outlines the steps that we have taken and constitutes the Group's anti-slavery and human trafficking statement for the financial year ending in 2023.

This statement is approved by our board of directors in a board meeting held on 12 February 2024 and has been signed off by the board on 19 February 2024.

Organisation's structure

The Group is a global provider of cybersecurity, software development, cloud, hardware, marketing, education, recruiting and training services. MacPaw Family Limited is the ultimate parent company of the Group. The Group has over 500 employees and operates in territories that include the US, Ukraine, and Cyprus. Further details about the Group are accessible here https://macpaw.com/about.

This statement is intended to cover the entities listed below, which currently meet the criteria for publishing this statement under the Modern Slavery Act 2015 and its subordinate legislation:

1. Macpaw Family Ltd: C/O Buzzacott LLP, 130 Wood Street, London, United Kingdom, EC2V 6DL.
2. Macpaw Way Ltd: 25 Serifou, Allure Center 11, Office No. 11-12, 2nd Floor, 3046 Zakaki, Limassol, Cyprus.

Our supply chains

Our supply chains include IT (cybersecurity, software development, cloud services, hardware, marketing, education and training), recruitment services, provision of our goods and services to end clients. Our supply chains operate from the following territories that include USA, United Kingdom, European Union, Ukraine.

Our policies on slavery and human trafficking

We are committed to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls.

Due diligence processes for slavery and human trafficking

Our comprehensive due diligence process against modern slavery and human trafficking encompasses the following core policies: the Code of Conduct and Corporate Ethics, Vendor Management, and Information Security.

As part of our initiative to identify and mitigate risk, we also have in place systems to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistleblowers.

Supplier adherence to our values and ethics

We have zero tolerance to slavery and human trafficking and expect all our business partners to share this approach. A copy of this statement is available on our website for our business partners to inspect. To ensure all those in our supply chain and contractors comply with our values and ethics, we carry out due diligence on all new suppliers, agents, consultants and contractors throughout our supply chain.

Our compliance team consists of the following departments:

• Legal.
• Finance.
• Human resources.
• Procurement.
• Sales.

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 our staff. We also require our business partners to provide training to their staff and suppliers and providers.