Modern Slavery and Human Trafficking Statement

Introduction

This statement sets out the steps that Initia Systems Limited ("Initia Risk", "we", "our", or "us") takes to ensure that slavery and human trafficking are not taking place in our business operations or supply chains. We publish it voluntarily and in the spirit of the Modern Slavery Act 2015; as a micro-business we are below the Act's mandatory turnover threshold.

Initia Systems Limited is incorporated in England and Wales (company number 15403848) with its principal office at 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, United Kingdom.

Our Business

Initia Risk is a software-as-a-service (SaaS) provider of governance, risk, and compliance (GRC) solutions for organisations primarily in the United Kingdom and Europe. The Company is operated by its founder, supported by occasional contractors and reputable suppliers; it is a primarily digital business and does not operate large or complex supply chains.

Our Supply Chains

Our supply chains are limited and primarily consist of:

• Cloud infrastructure and hosting services (Google Cloud Platform and other reputable providers)
• Software development tools and third-party software licences
• Professional services (legal, accounting, consulting)
• Equipment and, where applicable, office facilities
• Marketing and business-development services

Our Approach

We are committed to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business. In practice this means:

• Engaging only with established, reputable suppliers and expecting them to comply with applicable law, including the Modern Slavery Act 2015
• Confirming the right to work in the UK for anyone engaged by the Company
• Dealing directly with suppliers and contractors rather than through labour intermediaries

Due Diligence

To identify and mitigate the risk of modern slavery and human trafficking in our business and supply chains, we:

• Conduct proportionate due diligence on new suppliers before entering into contracts
• Review existing suppliers periodically
• Prefer suppliers who have their own modern-slavery statements or demonstrate ethical practices
• Use established, reputable cloud providers with strong ethical and compliance frameworks
• Engage workers and contractors directly rather than through labour providers or intermediaries

Risk Assessment

Given the nature of our business as a SaaS provider with a primarily digital supply chain and a small, direct operating model, we assess our risk of exposure to modern slavery and human trafficking as low. We remain vigilant and committed to reviewing our supply chains for changes that might increase risk, staying informed about modern-slavery risks in the technology sector, and taking appropriate action if concerns are identified.

Awareness

The director maintains awareness of modern-slavery risks in the technology sector and of how to recognise and report concerns.

Effectiveness and Future Steps

We will continue to review and enhance our approach so that it remains effective. In the coming year we plan to continue monitoring our supply chains, enhance supplier due diligence, and review and update this statement annually.

Approval

This statement has been approved by the director of Initia Systems Limited and will be reviewed and updated annually.

Signed on behalf of Initia Systems Limited
Director
June 2026