Modern Slavery and Human Trafficking Policy.

Statement – Financial Year 2025/2026

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps that DeterTech has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

1. Purpose and Statement of Commitment – At DeterTech, we are committed to acting ethically and with integrity in all areas of our business. We recognise the profound harm caused by modern slavery and human trafficking in its exploitation of vulnerable individuals and violations of fundamental human rights. We are therefore determined to play an active role in preventing and eradicating these practices through our business operations and our supply chain.

2. Scope and Applicability – This policy applies to all employees, agency workers, contractors, consultants, suppliers and business partners. It applies to all business operations, both in the UK and overseas.
In particular, this policy impacts our supply chain and recruitment processes where we have the most impact over being able to stop these practices.

3. Definitions – DeterTech ensure that all aspects of modern slavery are prevented from entering our supply chain and business operations. In particular, we note the following definitions:

• Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking.
• Exploitation may involve coercion, threats, deception or abuse of power.

4. Roles and Responsibilities – Senior management has overall responsibility for ensuring this policy complies with legal obligations.

Supply chain are responsible for ensuring that approved suppliers also commit to the prevention of both modern slavery and human trafficking. Through stringent on boarding and supplier management procedures, we are able to retain ethical accountability throughout all levels of our supply chain.

Through our recruitment and vetting procedures, we ensure that we do not directly employ infividuals who may have been subjected to trafficking or exploitation. The Human Resources Department are responsible for ensuring this continuing practice throughout our operations.

Managers are responsible for risk identification and employees must comply with this policy and report any concerns.

5. Risk Assessment – Our business risk is primarily focused on our supply chain and recruitment processes. We maintain a zero-tolerance approach to slavery, servitude, forced or compulsory labour, and human trafficking.

We regularly assess potential risk areas within our operations and supply chains, considering geographical locations, labour practices and the nature of services provided. We maintain a preference for working with suppliers based in low-risk territories.

We ensure that modern slavery and human trafficking are captured within our business risk register in order that the risks can be successfully managed and reviewed regularly.

Improving supplier relationships and the appropriate use of technology ensures that we appropriately manage the associated risks and help us to improve.

6. Due Diligence and Controls – We have established the following controls to manage risks:

• Supplier Onboarding and Audits: Our supply chain department
• Contractual Clauses: We include specific anti-slavery clauses in our supplier contracts to reinforce accountability.
• Recruitment & Vetting: Our Human Resources Department ensures that all direct employees are subject to rigorous vetting to prevent trafficking or exploitation.
• Whistleblowing: We provide established channels for employees and external parties to report concerns with a guarantee of confidentiality.
• Training: All employees receive initial and refresher training to raise awareness of modern slavery risks and ensure ongoing understanding

7. Reporting Concerns and Whistleblowing – Employees and external parties are encouraged to report concerns through established reporting or whistleblowing channels. All reports will be taken seriously and investigated using the company’s established whistleblowing processes.
Any report will be treated with the appropriate level of confidentiality and all findings and resolutions will be shared with the complainant for transparency.

8. Training and Awareness – Using our online training platform, DeterTech is able to ensure that all employees receive appropriate and consistent training.
Additional training may be offered to those engaged in high-risk roles such as supply chain if it is felt that this is an appropriate intervention.

9. Responding to Incidents – Where modern slavery or human trafficking is identified, we will take immediate action to protect affected individuals and work with relevant authorities where required. Each incident will be approached on its own merits to ensure the scope and scale of response is appropriate.

10. Monitoring and Review – Supplier auditing will take place regularly to ensure that the controls within our supply chain remain robust.

This policy will be reviewed at least annually to ensure its continued effectiveness and compliance with legislation and business practices.

11. Breaches of the Policy – Any breach of this policy may result in disciplinary action, up to and including termination of employment or contracts.

12. Approval and Ownership – This policy is owned by the Compliance function and approved by senior leadership. It has been seen and approved by the board of directors. The CEO signs this policy on behalf of the whole board. Dated 28 May 2026.

The policy is approved at the end of each financial year and confirms compliance for the preceding year.