Modern Slavery Statement

1. Background

Civo Limited is a company incorporated and registered in England and Wales with company number 09568551 whose registered office is at First Floor, 32-37 Cowper Street, London, England, EC2A 4AW (Civo).

Civo provides a future-proof cloud-native platform that integrates Kubernetes, IaaS, PaaS, DBaaS, Object Storage, WASM, GPUs and AI/ML capabilities, providing a comprehensive and scalable environment for cutting -edge computing needs. We champion innovation, open standards and sustainability. We don't lock our customers in. Step into the future with Civo.

2. Pursuant to the Modern Slavery Act 2015

The Modern Slavery Act 2015 came into effect on 29th October 2015. This law requires manufacturers and retailers doing business in the UK which supply goods or services and have an annual turnover exceeding £36 million to disclose information regarding their policies to eradicate slavery and human trafficking from their supply chain and within their business.

Civo takes its responsibility in this area very seriously and we have implemented robust controls and checks to ensure full and ongoing compliance with this important legislation.

3. Civo's Supply Chain

Civo maintains published policies that strictly prohibits the use of slave labour or human trafficking activities in its direct supply chains.

4. Due Diligence

Civo requires its key suppliers to complete an annual Supplier Assessment which is then reviewed and risk-assessed to ensure that they are compliant with the Act. Further, our Terms of Purchase place an obligation on our suppliers to warrant that they and their sub-contractors also comply in full with the Modern Slavery Act 2015 and other key legislation.

Civo's internal audit and compliance team will conduct regular reviews and report to the Leadership Team using key performance indicators.

5. Supplier Non-Compliance

Civo has a zero-tolerance policy towards Suppliers who fail to enact the laws banning forced labour, slavery and human trafficking. Our agreements enable the termination of suppliers for a single violation.

6. Written Policies and Procedures

Civo's Anti-Slavery and Human Trafficking Policy CIVO-POL-016 the rules and procedures by which all personnel should respect and treat their fellow employees. Human rights include normal expectations arising from the sanctity of life, including the provision and exercising of civil, political, economic and social rights. We respect and actively support:

1. the human rights of its employees, whether full-time, part-time, temporary or permanent
2. the human rights of those directly engaged by the Company, e.g. contractors and partners
3. the existence of rights at work, and a commitment to resolve employee grievances
4. the avoidance of complicity
5. the protection of vulnerable groups, and ensuring that no discrimination exists
6. the assurance that human rights are respected at all stages of the supply chain

7. Employee Training

Civo complies with a comprehensive set of employment and personnel-based policies and procedures, as well as all relevant employment legislation, covering the Modern Slavery Act 2015. All employees are made aware of their responsibility to comply with formal policies and procedures, and regular training is provided to reinforce this message.

8. Human Rights

Civo undertakes regular reviews to ensure that all areas of its business are compliant with its acceptable ethical and international human rights standards, and that all employees are treated in a fair, transparent and respectful manner. This includes adherence to the UK's Working Time Directive and the Minimum Wage.

9. Policy on actual or potential breaches

Civo's Anti Slavery and Human Trafficking Policy CIVO-POL-016 states that in the unlikely event of an actual or potential breach of the Anti-Slavery Act and Human Trafficking Act, related Company policies and procedures, or should clarification on any matter relating to the respect and support of this be sought, the Chief Executive Officer is to be consulted or Civo's Whistle Blowing Policy CIVO-POL-012 should be invoked.

10. Approval for this statement

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 31st March 2025.