1. Introduction
This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and outlines the steps that Spectro Cloud has taken, and continues to take, to ensure that modern slavery and human trafficking are not taking place within our business operations or supply chains.

We are committed to acting ethically and with integrity in all business dealings and relationships, and to implementing and enforcing effective systems and controls to prevent modern slavery.

2. Our Business and Structure
Spectro Cloud is a technology company that provides a Kubernetes management platform designed to simplify the deployment and lifecycle management of Kubernetes across cloud, data center, and edge environments. The company operates in the United States, the United Kingdom, and the European Union, delivering services to public and private sector organizations, including through frameworks such as the UK G-Cloud.

3. Our Supply Chains
Our supply chains primarily include providers of:

• Cloud infrastructure and hosting services
• Software and technology vendors
• Professional and consulting services
• Office and operational support services

While our supply chains are largely based in low-risk jurisdictions, we recognize that risks of modern slavery can exist in any sector and geography.

4. Our Policies on Modern Slavery
We maintain policies that reflect our commitment to ethical conduct and preventing modern slavery, including:

• Code of Conduct / Business Ethics Policy
• Supplier Code of Conduct (where applicable)
• Anti-Bribery and Corruption Policy
• Whistleblowing Policy

These policies set clear expectations for employees, contractors, and suppliers.

5. Due Diligence Processes
To identify and mitigate risks of modern slavery, we:

• Conduct due diligence on key suppliers and partners
• Evaluate suppliers based on risk factors such as geography and service type
• Include contractual provisions requiring compliance with applicable laws, including the Modern Slavery Act
• Review supplier practices where appropriate

6. Risk Assessment and Management
We assess modern slavery risk as part of our broader risk management processes. Factors considered include:

• Country risk
• Industry sector risk
• Nature of services provided

Where risks are identified, we take appropriate steps to address them, including enhanced due diligence or reconsideration of supplier relationships.

7. Training and Awareness
We provide awareness and guidance to relevant employees to help them identify and respond to potential indicators of modern slavery. This ensures that our workforce understands the importance of reporting concerns.

8. Reporting Concerns
We encourage employees, suppliers, and other stakeholders to report any concerns related to modern slavery. Reports can be made through our whistleblowing channels, and all concerns are taken seriously and investigated appropriately.

9. Continuous Improvement
We are committed to continuously improving our practices to combat modern slavery. This includes reviewing policies, enhancing due diligence processes, and monitoring developments in legislation and best practices.

10. Approval
This statement has been approved by senior management and will be reviewed annually.

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