Modern Slavery & Human Trafficking Statement

Financial Year: 2025–2026

Date Published: 12th December 2025

Approved by: Board of Directors

Company: APM Technologies SA

Next Review Date: December 2026 Contents

Introduction

This Modern Slavery and Human Trafficking Statement is published by APM Technologies in accordance with the requirements of the UK Modern Slavery Act 2015, Section 54(1).

Although the organisation’s turnover falls below the £36 million statutory reporting threshold, APM Technologies voluntarily publishes this statement as part of its commitment to ethical business practices, transparency, and respect for human rights across all areas of our operations and supply chain.

APM Technologies maintains a zero-tolerance approach to modern slavery, human trafficking, forced labour, child labour, and all forms of exploitation. We are committed to ensuring that these abuses have no place in our business and that the people who work for us, with us, or on behalf of us are treated with dignity, fairness, and respect.

This statement sets out the steps taken during the 2024–2025 financial year and outlines our commitments for 2025–2026 to further strengthen our controls and reduce risks.

Our Organisation

APM Technologies is a technology and software development organisation providing:

• Aviation and operational software solutions
• Systems integration and digital transformation products
• Software development and support services
• Technical consulting and cloud-based platforms

We operate across multiple regions including the United Kingdom, Europe, and other international delivery locations, supported by a distributed workforce of employees, contractors, developers, consultants, and specialist technology partners. Our values include: Integrity and transparency in all business relationships Respect for individuals, regardless of geography or employment status

• Responsible sourcing and fair labour practices
• Commitment to global ethical standards in technology supply chains
• Continuous improvement of our governance and compliance systems

Because our company operates primarily as a remote-first, technology-focused organisation, we are not directly exposed to high-risk sectors such as manufacturing, construction, or agriculture. However, we recognise that modern slavery risks still exist in certain areas of the technology sector, particularly in:

• Hardware manufacturing supply chains
• Offshore software development
• Freelance and contract labour arrangements
• Third-party support and infrastructure services
• Recruitment and labour brokering in overseas markets

We therefore take active steps to identify, prevent, and mitigate these risks.

Our Supply Chain

APM Technologies’ supply chain consists primarily of:

• Independent software developers and freelance contractors
• Specialist technical consultants
• Cloud service providers and hosting platforms
• Software and SaaS vendors (e.g., productivity, development, and testing tools)
• Professional services (legal, HR, accounting, design, marketing)
• IT hardware suppliers (laptops, peripherals, networking equipment)
• Third-party development partners in the UK, EU, India, and other regions

While our supply chain does not include high-risk manual labour environments, modern slavery can occur in long and opaque supply networks, including:

• Electronic component manufacturing
• Hardware assembly facilities
• Subcontracted IT service providers
• Labour recruiters in high-risk countries
• Gig-economy-based freelance platforms

We are therefore committed to monitoring and managing these risks proportionately.

Risk Assessment and Due Diligence

During the 2024–2025 reporting year, we conducted structured due diligence activities across our operations.

Supply Chain Risk Mapping We undertook:

• A review of tier-1 suppliers using recognised international risk indices (ILO, GLAA, U.S. Department of Labor, and Global Slavery Index)
• Assessment of cloud hosting and infrastructure providers for ethical sourcing policies
• Analysis of recruitment and labour sourcing practices for contractors This exercise identified no elevated risk indicators in hardware supply chains and in some freelance contractor markets, no cases of exploitation or non-compliance were identified.

Supplier Onboarding

Controls All new suppliers, contractors, and partners must:

• Agree to the APM Technologies Supplier Code of Conduct
• Confirm that they do not use forced, bonded, compulsory or child labour
• Commit to fair wages, ethical recruitment, and safe working conditions
• Declare compliance with all applicable labour laws in their jurisdiction
• Provide assurance that no recruitment fees are charged to workers High-risk suppliers may be asked to complete additional due diligence questionnaires or provide evidence of policies.

Contractual Protections

All supplier and contractor agreements contain:

• Explicit prohibitions on modern slavery and human trafficking
• Rights for APM Technologies to terminate relationships where breaches occur
• Requirements that subcontractors also comply with equivalent standards
• Terms requiring free movement of labour and prohibition of document retention 4.4 Internal Employment Safeguards We ensure:
• All staff and contractors have legal rights to work
• No withholding of passports, identification, or deposits
• No use of bonded or dependent labour arrangements
• Fair wages aligned to or exceeding local market standards
• Freedom for employees and contractors to terminate employment with notice
• Remote-first working, reducing risks associated with accommodation dependency

Training and Awareness

APM Technologies recognises that training is essential in identifying and preventing modern slavery. In the 2024–2025 period:

• All employees and contractors are briefed on the importance of this subject
• Managers underwent enhanced training on identifying warning signs and escalation procedures
• Modern slavery guidance will now form part of the onboarding materials for new staff

We will continue to provide annual refresher coaching to maintain a high level of awareness.

Policies and Governance

Our approach to preventing modern slavery is supported by a range of internal policies, including:

• Modern Slavery & Human Trafficking Policy
• Supplier Code of Conduct
• Whistleblowing Policy, including anonymous reporting channels
• Ethical Recruitment Policy
• Equal Opportunities and Diversity Policy
• International Employment Practices Policy The Board of Directors retains ultimate accountability for modern slavery compliance. Senior management is responsible for implementation across functions, operations, and supply chains.

Monitoring, KPIs and Performance

In 2025–2026, we aim to introduce:

• Periodic desk-based audits or medium-risk suppliers
• A strengthened supplier onboarding questionnaire
• Tracking of supplier compliance breaches or concerns
• Annual Board report KPI reviewing supply chain risks

Commitment to Continuous Improvement

APM Technologies recognises that modern slavery risk is dynamic and requires constant vigilance. Over the next reporting period, we will:

• Extend risk mapping to tier-2 suppliers and subcontractors
• Develop an ethical international contractor engagement process
• Enhance supplier compliance, prioritising higher-risk categories
• Engage with industry networks to identify best practices
• Provide additional training focused on technology supply chain risks
• Strengthen monitoring of offshore and freelance labour recruitment channels
• Explore partnerships with NGOs focused on technology sector labour rights

Reporting and Escalation

Individuals—whether employees, contractors, partners, or suppliers—may report concerns anonymously via our Whistleblowing channel or by contacting:

Email: compliance@apmtechnologies.com
Website: www.apmtechnologies.com/modern-slavery

APM Technologies will investigate all concerns thoroughly and take appropriate action, including ending supplier relationships where non-compliance is confirmed.

Approval

This statement has been approved by the Board of Directors of APM Technologies and will be reviewed annually.

Name: Laurent Reymond
Position: Director
Date: 12th December 2025