Updated 25th June 2025

Modern Slavery and Human Trafficking Statement

Introduction

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 December 2024. Approved Technology Limited ('the Company', 'we', 'us' or 'our') is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

Organisational Structure

Approved Technology Limited offices are based in the United Kingdom but we ship and procure globally. We operate in the IT Component Distribution sector. The nature of our supply chain is as follows: We work only with a select number of core direct suppliers for goods and services.

Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

These include the following:

Recruitment and selection policy - Ensuring that staff involved in the recruitment and deployment of workers receive training on modern slavery and ethical employment practices.
Supplier code of conduct - Our supplier code of conduct and supplier contracts make explicit reference to slavery and human trafficking legislation and compliance.
Whistleblowing policy - We have a written policy whereby all employees and suppliers are required to report any suspicion of slavery or human trafficking without fear of retaliation.
Staff code of conduct - Our staff code of conduct clearly states the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating and managing our supply chain.
Procurement policy - We conduct due diligence investigations on all new suppliers during on-boarding and on existing suppliers at regular intervals.
Safeguarding policy - Prevent abuse and neglect where possible. Our safeguarding policy provides a consistent approach when responding to safeguarding concerns. Defined duties and responsibilities help to make sure there is a consistent approach to safeguarding within our business and supply chain.

We make sure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

Internal supplier audits.
External supplier audits.

Our due diligence procedures aim to:

Identify and action potential risks in our business and supply chains.
Monitor potential risks in our business and supply chains.
Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
Provide protection for whistleblowers.

Risk and Compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its supply chain through:

Evaluating the slavery and human trafficking risks of each new supplier.
Creating an annual risk profile for key suppliers.
Reviewing on a regular basis all aspects of the supply chain.

We consider that we operate in a low-risk environment because our chain is in low-risk industries such as Information Technology Products and Services. We conduct audited visits to our supply chain partners within every 24 month period.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.

Effectiveness

The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

We will contact suppliers to enquire about their modern slavery practices every 12 months.
We will train our staff about modern slavery issues and increase awareness within the Company.
We will carry out a regular audit of suppliers - 100% of suppliers each year.

Training Staff

The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The Company's training covers:

How to identify the signs of slavery and human trafficking.
What initial steps should be taken if slavery or human trafficking is suspected.
How to escalate potential slavery or human trafficking issues to the relevant parties within the Company.
What external help is available.
What steps the Company should take if suppliers in its supply chain do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company's supply chain.

This statement covers the financial year period 1 January to 31 December 2025 and has been approved by the Board of Directors.