Modern Slavery and Human Trafficking Statement

1. Introduction

This statement sets out the steps taken by Nanosoft Corporation Limited ("Nanosoft", "we", "our") to identify and prevent modern slavery and human trafficking within our business and supply chain during the financial year ending 31 March 2026.

Nanosoft is not legally required to publish a statement under Section 54 of the Modern Slavery Act 2015, as our annual turnover falls below the £36 million threshold at which such a statement becomes mandatory. We nonetheless publish this statement voluntarily, and having regard to the principles of Section 54, because we believe transparency and ethical conduct are the right standards to hold ourselves to and are important to the clients and public sector bodies we serve.

We have a zero-tolerance approach to modern slavery and human trafficking and are committed to acting ethically and with integrity in all our business dealings and relationships.

2. Organisation Structure and Business

Nanosoft is a specialist provider of IT Asset Disposition (ITAD) services. Our activities include:

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

We operate from a single site in Maldon, Essex, with a directly employed workforce. We serve enterprise and public sector clients across a range of sectors. Our operations involve the collection, processing, refurbishment, resale and responsible disposal of IT equipment.

The large majority of our activity is the refurbishment and responsible disposal of equipment decommissioned by UK organisations. Alongside this, we supply IT devices and hardware, and we source used equipment from international markets for refurbishment and resale.

Our operations are supported by ISO-certified management systems, ISO 9001, ISO 14001, ISO 45001 and ISO 27001, which reinforce our commitment to responsible, safe and well-governed operations.

3. Our Supply Chains

Our supply chains include:

• IT equipment collection and logistics partners
• Component and replacement parts suppliers
• Suppliers of new and used IT devices and hardware
• 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 are complex and involve multiple tiers of suppliers across different geographical regions, including areas where the risk of modern slavery is higher. Our device supply activity and our sourcing of used equipment from international markets connect our supply chain, indirectly and at several removes, to global electronics manufacturing and to the extraction of the raw materials used in electronic components. This is where the greater part of our modern slavery risk sits, rather than in our own operations.

4. Our Policies

We maintain the following policies to help ensure that modern slavery and human trafficking do not take place in our business or supply chains.

4.1 Code of Conduct

Our Code of Conduct (NS-POL-COC-001) sets out the standards of behaviour expected from all directors, employees, workers, temporary and agency staff and contractors. It explicitly prohibits any form of forced, bonded or compulsory labour, child labour or human trafficking, and requires everyone to be alert to the signs of exploitation and to raise concerns.

4.2 Supplier Code of Conduct

Our Supplier Code of Conduct (NS-POL-SCC-001) applies to all suppliers, subcontractors, carriers and downstream recycling partners. It requires that employment is freely chosen, that workers keep control of their own identity and travel documents, that wages are paid in full and on time and are not withheld as a means of control, that workers pay no recruitment fees, and that no child labour is used. It also requires suppliers to flow equivalent standards down to their own subcontractors.

4.3 Whistleblowing Policy

Our Whistleblowing Policy (NS-POL-WB-001) provides a confidential route for employees, contractors and suppliers, and their workers, to report suspected modern slavery, human trafficking or labour exploitation without fear of retaliation. Modern slavery is named expressly as a reportable concern.

5. Due Diligence Processes

We carry out due diligence on our suppliers and business partners to assess and mitigate the risk of modern slavery and human trafficking. Our due diligence includes:

• Risk assessment of new suppliers before engagement
• Contractual requirements for suppliers to comply with modern slavery legislation and our Supplier Code of Conduct
• Assessment and review of higher-risk suppliers, proportionate to the goods or services they provide
• Requests for evidence such as policies, permits, licences and insurances
• Investigation of any concerns or allegations raised
• Corrective action plans where gaps are found, and ending relationships with suppliers who fail to meet our standards

6. Risk Assessment and Management

We assess where the risk of modern slavery and human trafficking is most likely to arise, and we distinguish between our own operations and our wider supply chain.

6.1 Our own operations

We consider the risk within our own operations to be low. We operate from a single UK site with a small, directly employed workforce. We do not operate overseas and we do not rely on labour providers or outsourced labour for our core processing activity. We nonetheless remain alert to the signs of exploitation and expect our people to raise concerns.

6.2 Our supply chain

We recognise elevated risk in the upstream electronics supply chain. In particular, we consider the following to present a higher risk of modern slavery, and these are the locations we have identified in our supply chain risk assessment:

We also recognise risk in labour-intensive refurbishment and processing operations, in transportation and logistics services, and in subcontracted services and temporary labour.

6.3 How we manage it

Our strong bias toward the reuse and refurbishment of existing equipment, rather than the procurement of newly manufactured equipment, materially reduces our exposure to the risks in upstream manufacturing. Where we do source devices and used equipment, we apply the due diligence set out in section 5 and require compliance with our Supplier Code of Conduct. We review these areas and implement controls and monitoring proportionate to the risks we identify.

7. Training and Awareness

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

• Procurement and supplier management
• Operations and logistics
• Recruitment and people management
• Compliance and risk management

This includes guidance on identifying the signs of modern slavery, understanding reporting procedures and recognising our responsibilities in relation to the Modern Slavery Act 2015. New starters are briefed on our Code of Conduct, which covers modern slavery, as part of induction. Training is recorded.

8. Measuring Effectiveness

We measure the effectiveness of our actions through:

• Review of supplier compliance with our Supplier Code of Conduct
• Monitoring of whistleblowing reports and investigation outcomes
• Review of awareness and training activity
• Annual review of this statement and our related 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 for higher-risk suppliers, particularly those connected to the locations identified in section 6
• Enhance awareness and training activity
• Work with suppliers to improve their understanding and compliance
• Engage with partners and stakeholders
• Report openly on our progress

10. Approval and Review

This statement has been approved by the Board of Directors of Nanosoft Corporation Limited and will be reviewed annually, and sooner where there is a material change to our operations, obligations or risks.

Signed on behalf of the Board of Directors