Modern Slavery and Human Trafficking Statement

Stack Solutions HQ Limited

Financial Year Ended: 30 April 2026

Approved by: Senior Management Team

1. Introduction

This Modern Slavery and Human Trafficking Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps taken by Stack Solutions HQ Limited (“the Company”) to prevent modern slavery, forced labour, and human trafficking within its operations and supply chains.

The Company is committed to conducting business ethically, transparently, and in compliance with applicable legal and regulatory requirements. This commitment is embedded within the Company’s wider governance and information security framework.

2. Organisational Structure and Supply Chains

Stack Solutions HQ Limited is a UK-based organisation providing technology-enabled services and operational support to its clients.

The Company’s supply chain consists primarily of third-party service providers required to support business operations, including:

Cloud infrastructure and software providers

Technology and communication platform vendors

Professional and consultancy service providers

General business service suppliers

Supplier relationships are managed in accordance with the Company’s Supplier Relationship Security Policy, which applies risk-based categorisation and due diligence proportional to supplier access and criticality.

3. Policies Relevant to Modern Slavery

The Company maintains a set of internal policies which collectively support the prevention of modern slavery and unethical labour practices, including:

Human Resource Security Policy

Supplier Relationship Security Policy

Information Security Policy

Incident Management Policy (for escalation of relevant compliance concerns)

These policies establish expectations for lawful employment practices, ethical conduct, and supplier compliance with applicable legislation.

4. Due Diligence and Supplier Controls

The Company applies a risk-based due diligence approach in line with its Supplier Risk Tiering framework:

Tier 1 (Critical Suppliers): Subject to enhanced due diligence, including review of recognised independent security and compliance reports (e.g. ISO 27001 / SOC 2 Type II where applicable).

Tier 2 (Operational Suppliers): Subject to standard due diligence, security questionnaires, and contractual compliance confirmation.

Tier 3 (Low Risk Suppliers): Managed via standard contractual arrangements with proportionate review.

All suppliers are required, where appropriate, to confirm compliance with applicable anti-slavery and human trafficking legislation as part of contractual onboarding.

Where suppliers have access to sensitive data or systems, controls defined in the Supplier Relationship Security Policy apply, including access limitation, monitoring, and audit rights where contractually feasible.

5. Risk Assessment and Management

The Company recognises that modern slavery risks may exist within global supply chains and therefore adopts a proportionate, risk-based approach to mitigation.

The Company considers its direct operational risk to be low due to the nature of its activities. However, it acknowledges indirect risk exposure through third-party suppliers and service providers.

Risk factors considered include:

Supplier geography

Nature of services provided

Level of access to systems or data

Supplier criticality within Tier 1–3 classification

Where elevated risk is identified, additional due diligence measures may be applied in line with the Supplier Relationship Security Policy.

6. Employment Practices and Human Resources Controls

The Company maintains employment controls designed to reduce the risk of unethical labour practices, including:

Right to work verification

Background screening proportionate to role sensitivity

Contractual obligations requiring compliance with Company policies

Mandatory policy acceptance and onboarding procedures

Security awareness training for relevant personnel

These measures are defined within the Company’s Human Resource Security Policy and apply to employees, contractors, and temporary staff.

7. Reporting and Escalation

The Company maintains formal processes for the reporting and escalation of concerns relating to unethical conduct, including modern slavery risks.

All personnel are required to report suspected violations through designated internal reporting channels. Reported concerns are assessed and managed in accordance with the Information Security Incident Management Policy, where relevant, or escalated to the appropriate governance function, including the Data Protection / Privacy function where applicable.

8. Training and Awareness

Relevant personnel involved in procurement, supplier management, and human resources receive appropriate training and guidance on identifying and responding to potential indicators of modern slavery and unethical labour practices.

Awareness is maintained through onboarding processes, internal policies, and periodic compliance updates.

9. Monitoring and Continuous Improvement

The Company is committed to continuous improvement of its governance and supplier oversight processes.

Supplier relationships are periodically reviewed in accordance with the Supplier Relationship Security Policy. Where improvements are identified, proportionate corrective actions are implemented.

The Company will continue to refine its controls in line with evolving regulatory expectations and industry best practice.

10. Approval and Governance

This statement has been approved by the Board of Directors of Stack Solutions HQ Limited and is subject to annual review.

The Company remains committed to ensuring that modern slavery and human trafficking have no place within its operations or supply chain.