Modern Slavery & Human Trafficking Statement

1. Introduction

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes NanoSoft's slavery and human trafficking statement for the financial year ending 31 December 2026.

NanoSoft is committed to preventing modern slavery and human trafficking in all its forms within our business and supply chain. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships.

2. Organisation Structure and Business

NanoSoft is a leading provider of IT Asset Disposition (ITAD) services, specialising in:

• IT Asset Disposition and lifecycle management
• Secure data destruction services
• Data centre decommissioning
• IT equipment refurbishment and remarketing
• Environmental recycling and waste management

We operate primarily in the United Kingdom, serving enterprise clients across various sectors. Our operations involve the collection, processing, refurbishment, and disposal of IT equipment.

3. Our Supply Chains

Our supply chains include:

• IT equipment collection and logistics partners
• Component and replacement parts suppliers
• Software licensing providers
• Certified recycling and disposal partners
• Transportation and warehousing services
• Professional services and contractors

We recognise that supply chains in the technology sector can be complex and may involve multiple tiers of suppliers across different geographical regions, including areas where modern slavery risks may be higher.

4. Our Policies

We have implemented the following policies to ensure modern slavery and human trafficking do not occur in our business or supply chains:

4.1 Code of Conduct

Our Code of Conduct sets out the standards of behaviour expected from all employees, contractors, and business partners. It explicitly prohibits any form of forced labour, child labour, or human trafficking.

4.2 Supplier Code of Conduct

We require all suppliers to adhere to our Supplier Code of Conduct, which includes specific provisions against modern slavery and human trafficking. Suppliers must demonstrate their commitment to ethical business practices and compliance with applicable laws.

4.3 Whistleblowing Policy

We maintain a confidential whistleblowing procedure that enables employees, contractors, and suppliers to report concerns about suspected modern slavery or human trafficking without fear of retaliation.

5. Due Diligence Processes

We conduct due diligence on our suppliers and business partners to assess and mitigate the risk of modern slavery and human trafficking. Our due diligence processes include:

• Risk assessment of new suppliers before engagement
• Contractual requirements for suppliers to comply with modern slavery legislation
• Regular audits and assessments of high-risk suppliers
• Investigation of any concerns or allegations raised
• Termination of relationships with suppliers who fail to meet our standards

6. Risk Assessment and Management

We recognise that certain areas of our supply chain may present higher risks for modern slavery and human trafficking, including:

• Component manufacturing in high-risk geographical regions
• Labour-intensive refurbishment and processing operations
• Transportation and logistics services
• Subcontracted services and temporary labour

We conduct regular risk assessments of these areas and implement appropriate controls and monitoring measures to mitigate identified risks.

7. Training and Awareness

We provide training and raise awareness about modern slavery and human trafficking among our employees, particularly those involved in:

• Procurement and supplier management
• Operations and logistics
• Human resources and recruitment
• Compliance and risk management

Training includes guidance on identifying signs of modern slavery, understanding reporting procedures, and recognising our responsibilities under the Modern Slavery Act 2015.

8. Effectiveness Measurement

We measure the effectiveness of our actions to combat modern slavery and human trafficking through:

• Regular review of supplier compliance with our Supplier Code of Conduct
• Monitoring of whistleblowing reports and investigation outcomes
• Assessment of training completion rates and effectiveness
• Annual review of this statement and our anti-slavery policies
• Engagement with industry bodies and best practice initiatives

9. Our Commitment

We are committed to continuous improvement in our approach to identifying and preventing modern slavery and human trafficking. We will:

• Regularly review and update our policies and procedures
• Strengthen due diligence processes for high-risk suppliers
• Enhance training and awareness programmes
• Engage with suppliers to improve their understanding and compliance
• Collaborate with industry partners and stakeholders
• Report transparently on our progress and challenges

10. Approval and Review

This statement has been approved by the Board of Directors of NanoSoft and will be reviewed annually. Any questions or concerns regarding this statement should be directed to: