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Modern Slavery & Human Trafficking Statement

It continues to be a priority for Mindera to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain.

This statement sets out Mindera's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

Our business

Mindera is a provider of services in the technology sector. We are a part of the Mindera group of companies (Group) which operates from locations around the world, with our ultimate parent company having its head office in the UK.

Our supply chains

We are a technology business providing services to businesses worldwide. Our workforce is highly skilled, due to the technical nature of our offering, and we have a relatively small supply chain. Mindera operates with strategic and critical suppliers. Our supply chain is largely characterised by the purchase of IT and technology, software licences, telecoms, communications, marketing, and professional services.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.

Our specific policies on key social and ethical issues, for example, our Human Rights and Labour and our Anti-Bribery and Corruption policies, outline the standards and behaviours that we expect from all our people, wherever they are in the world, whatever local practices are and wherever they conduct business on behalf of the organisation. We regularly review and update all our policies.

Mindera encourages all its people, customers and other business partners to report any concerns related to the direct activities, or the supply chains of the organisation. The organisation's whistleblowing procedure is designed to make it easy for everyone to make disclosures, without fear of retaliation.

Due diligence processes for slavery and human trafficking

We have undertaken a proportionate risk assessment in line with the requirements of the Modern Slavery Act 2015. Due to the nature of our business and the skill levels required from our people and business partners we believe that our business and supply chains are at a ‘low risk’ of potential for slavery or trafficking.

We understand that the highest modern slavery risk for Mindera comes from its people. We therefore have a number of processes in place to verify the identity of our workforce to make sure we know exactly who is working for us. We carry out appropriate checks on all our people which may include reference, qualification and licence checks, depending on their role.

As part of our ongoing work to identify and mitigate risk we have put in place systems to:

  • Identify and assess potential risk areas in our supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains.
  • Monitor potential risk areas in our supply chains.
  • Protect whistle blowers.

We have a dedicated compliance team which consists of representatives from the following departments

  • People Operations
  • Legal
  • Security

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 regular specific training on this subject to all our staff.

Our effectiveness in combating slavery and human trafficking

Following a review of the effectiveness of the steps we have taken in 2024 to ensure that there is no slavery or human trafficking in our supply chains, Mindera commits to:

  • continuously assessing and reviewing its exposure to slavery and trafficking risks across the Group’s supply chain and taking the necessary steps to mitigate any risks identified; and
  • annually publishing progress and developments within the Group’s practices in relation to the objectives of the Modern Slavery Act 1995.

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 December 2024. It was approved by the Mindera Board on 31 March 2025.