Anti-Slavery &

1. Purpose

SwiftTrack Digital Ltd is committed to conducting its business ethically and responsibly and to preventing modern slavery, human trafficking, forced labour and exploitation within its operations and supply chain.

We recognise that modern slavery can occur in many forms and that all organisations have a role in identifying and reducing the risk of exploitation.

2. Scope

This policy applies to directors, employees, contractors and others working for or on behalf of SwiftTrack Digital Ltd. It also sets out the standards we expect from suppliers, service providers and other business partners.

As a SaaS company, our principal activities involve the development, hosting, support and provision of digital software services. Our supply chain primarily includes technology, hosting, software, professional services and general business suppliers. We take a proportionate, risk-based approach to modern slavery within these relationships.

3. Our Commitment

SwiftTrack Digital Ltd will not knowingly engage with, support or benefit from any organisation involved in slavery, servitude, forced or compulsory labour, human trafficking or other forms of exploitation.

We are committed to:

• conducting our business with integrity and in accordance with applicable law;
• treating people working for or on behalf of SwiftTrack Digital Ltd fairly and with dignity and respect;
• not tolerating forced labour, human trafficking, unlawful child labour or exploitative working practices;
• considering modern slavery risks when appointing and reviewing suppliers and contractors where appropriate;
• expecting suppliers and business partners to comply with applicable employment and modern slavery legislation; and
• taking appropriate action where credible concerns about modern slavery or exploitation are identified.

4. Suppliers and Due Diligence

SwiftTrack Digital Ltd recognises that the level of modern slavery risk varies according to the nature of the goods or services being purchased, the location of the supplier and the structure of the supply chain.

We will apply proportionate due diligence when selecting or reviewing suppliers. This may include considering the supplier's location and activities, reviewing relevant policies or contractual commitments, seeking assurances where a higher risk is identified, and taking account of any credible information relating to unethical labour practices.

Where appropriate, SwiftTrack Digital Ltd may require suppliers or contractors to confirm that they comply with applicable modern slavery and employment legislation.

5. Employees and Contractors

SwiftTrack Digital Ltd expects all employees and contractors to act ethically and to be alert to circumstances that could indicate exploitation or unacceptable labour practices.

No person working for SwiftTrack Digital Ltd should knowingly participate in, facilitate or ignore modern slavery or human trafficking.

6. Reporting Concerns

Anyone working for or on behalf of SwiftTrack Digital Ltd who becomes aware of, or reasonably suspects, modern slavery, human trafficking or exploitative labour practices connected with our operations or supply chain should raise the concern promptly with a Director.

Concerns will be treated seriously and considered sensitively. No person should suffer detrimental treatment for raising a genuine concern in good faith.

7. Responding to Identified Risks

Where a credible concern is identified, SwiftTrack Digital Ltd will consider the circumstances and take appropriate and proportionate action. This may include seeking further information or assurances, requiring corrective action, suspending or ending a supplier relationship, or referring the matter to an appropriate authority where necessary.

Our priority will be to act responsibly and avoid action that could unnecessarily increase the risk of harm to affected individuals.

8. Responsibility

The Directors have overall responsibility for this policy and for ensuring that appropriate arrangements are in place to manage modern slavery risks relevant to SwiftTrack Digital Ltd.

Everyone working for or on behalf of the company has a responsibility to support the principles of this policy and report concerns where they arise.

9. Communication and Review

This policy will be made available to relevant employees, contractors, clients, suppliers and other interested parties as appropriate.

SwiftTrack Digital Ltd will review this policy annually and earlier where there are significant changes to our activities, supply chain, legal requirements or identified risks.

10. Modern Slavery Statement

This policy sets out SwiftTrack Digital Ltd's approach to preventing modern slavery and human trafficking. Where the company becomes subject to a legal requirement to publish an annual modern slavery statement, the Directors will ensure that the required statement is prepared, approved and published in accordance with applicable legislation.