Modern Slavery Act Statement

Approved by the Board of Directors, OpenKit Ltd
Date: 2nd December 2024

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st March 2024.

1. Policy Statement

OpenKit Ltd has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

This policy is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our company’s slavery and human trafficking statement for the current financial year.

2. Our Business

OpenKit is a provider of artificial intelligence consultancy services, bespoke software development, and digital transformation solutions, specialising in AI agent development, generative AI, large language models, and web and mobile applications. We are proud to be certified to ISO 9001 (Quality Management) and ISO 27001 (Information Security Management) standards. These certifications underscore our commitment to operational excellence, security, and maintaining the highest ethical standards in every aspect of our work.

3. Our Commitment

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers, and other business partners.

As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

4. Scope of the Policy

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

5. Responsibility for the Policy

The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The management team is responsible for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

6. Due Diligence and Risk Assessment

As part of our initiative to identify and mitigate risk, we operate a range of policies and procedures appropriate to our business. These include:

Supplier Vetting: We conduct due diligence on new suppliers and review our existing suppliers. We expect them to operate with the same ethical standards we employ. This includes particular attention to:

• Data annotation and labelling services
• Cloud infrastructure and hosting providers
• Hardware suppliers and equipment manufacturers
• Offshore development partners and subcontractors
• Third-party AI model and dataset providers

Contractual Clauses: Our supplier contracts contain clauses requiring them to comply with all applicable laws and regulations, including the Modern Slavery Act. These contracts specifically address the ethical sourcing of training data and the working conditions of any personnel involved in data processing or annotation services.

Whistleblowing: We have a robust whistleblowing policy that encourages all our staff, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

Regular Monitoring: We conduct periodic reviews of our supply chain, with particular focus on higher-risk areas such as data processing services, hardware procurement, and international partnerships.

7. 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 relevant members of staff. All directors have been briefed on the subject.

Training covers:

• Recognition of potential indicators of modern slavery and human trafficking
• Understanding of supply chain risks specific to the technology sector
• Procedures for reporting concerns
• Our commitment to ethical business practices

8. Reporting Concerns

The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

If you believe or suspect that a conflict with this policy has occurred, or may occur in the future, you must notify your manager or a company director as soon as possible. All reports will be treated with the utmost confidentiality, and we are committed to ensuring no one suffers any detrimental treatment as a result of reporting a concern in good faith.

Reports can be made through:

• Direct communication with line management
• Contact with any director
• Our confidential whistleblowing procedure
• Email to: contact@openkit.co.uk

9. Breaches of This Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

This policy will be reviewed and updated annually.

Company Registration No: 13030838