Anti-Slavery Statement

Pursuant to s54 of the Modern Slavery Act 2015, this Policy Statement confirms the steps Luminance Technologies Ltd (“We”) has taken and will continue to take to prevent modern slavery and human trafficking in any part of our business and supply chain.

Our Business & Risk

Luminance Technologies Ltd operates offices in the UK and US as a hosted technology company. We consider the risk of modern slavery and human trafficking within our business and supply chains to be very low, given our business locations, supplier bases, and industry sector.

Our Policies

We have policies in place designed to:

• Keep relevant staff aware of slavery and trafficking risks in our operations and supply chains;

• Monitor potential risk areas in our business and supply chains;

• Reduce the risk of slavery and trafficking occurring in our business and supply chains; and

• Provide protection for whistleblowers.

Our Supply Chain

Our supplier selection processes include checks for modern slavery risks. Staff conducting supplier selection must perform due diligence, including supplier inquiries, policy reviews, employee handbook requests, and physical workplace verification where necessary.

Our supplier contracts include commitments requiring effective systems to prevent slavery and trafficking. Suppliers must provide summaries of the prevention steps they take, their relevant policies, and details of their own supplier due diligence.

Our Employee Handbook establishes our expectations of conduct. Our HR team ensures compliance with applicable laws in the territories in which we operate and uses only reputable employment agencies. We place emphasis on maintaining a positive work environment and organisational culture.

Training

Staff are advised to exercise heightened care regarding organisations providing services from higher-risk regions and must immediately notify our legal and HR teams of any concerns so that appropriate action can be taken.