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Modern Slavery Statement

Financial year ending 30 September 2023

Xiatech (“we”, “us”) is absolutely committed to ensuring that there is no modern slavery or human trafficking in our business or supply chains, and to preventing modern slavery and human trafficking in our corporate activities. This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the potential risks related to our business and the steps that we have taken, and will continue to take, to ensure that modern slavery and human trafficking are not taking place within any part of our business.

Our Business and Supply Chain

Xiatech and the Xfuze Platform is a global brand, providing data and software solutions as well as services and related items to our customers worldwide. Business activities include the design, development, and delivery of technology and data solutions.

We work directly with a number of technology partners and independent contractors globally. We carry out development work in the UK, Poland, Bulgaria and Lithuania. We have established long-term relationships with several of our partners and have built these relationships over many years in most cases. This enables us to gain a deeper understanding of the issues faced by our suppliers.

Due Diligence

The primary risk for our business is in association with our suppliers in relation to sourcing from countries outside of the UK. As part of our initiative to identify and mitigate risk, we undertake due diligence on suppliers.

Supplier Reviews

We undertake due diligence when considering new suppliers to take on and regularly review our existing suppliers. We assess our suppliers to evaluate particular geographical risks of modern slavery and human trafficking. We work closely with our suppliers to understand their processes and we make it a contractual requirement that all suppliers we do business with sign our Code of Conduct.

Employees from our London head office regularly visit all our suppliers. This gives us invaluable insight into working practices, processes and conditions across our suppliers, allowing us to spot potential issues relating to modern slavery and human trafficking. In some cases we operate in shared working environments. We work with our partners in spotting and addressing modern slavery and human trafficking issues.

Employee/Worker Due Diligence

In each country where we employ staff, we ensure our compliance with the relevant employment legislation. We recruit and select our own workers and determine the terms and conditions of their employment. Employees/workers are free to accept or reject any employment offers made. As part of our recruitment process, we undertake checks on all workers to verify their identity, age and eligibility to work in that country.

We always aim to pay our workers a reasonable and fair wage for the job they are doing, and this will be at or above the legal minimum wage in the country they are employed. We require the same standards from our suppliers, and we confirm this through our audits. We also require the same or equivalent standards from our technology partners.

Relevant Policies

Whistleblowing Policy

We strongly encourage all our workers and business partners to report any concerns related to our activities or activities within our supplier and partner base. Our whistleblowing policy ensures that all workers know that they can raise concerns about how workers are being treated, or practices within our business or supply chain. This includes any circumstances that may give rise to an enhanced risk of modern slavery and human trafficking. This policy is designed to make it easy for workers to make disclosures, without fear of reprisals.

Code of Conduct

We are committed to ensuring that our suppliers and partners adhere to the highest standards of ethics. We require all suppliers and partners to sign our Code of Conduct, which mandates the following: safe and sanitary working conditions; no forced labour; no child labour; no harassment or abuse; no discrimination; freedom of association and collective bargaining; payment of at least minimum legal wage; and working hours that are not excessive.

Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the Code and improve their workers’ working conditions. Serious violations of our Code of Conduct would lead to the termination of the business relationship.

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