Modern Slavery and Human Trafficking Statement

1. Introduction

SmartGenie Ltd is committed to conducting business ethically, responsibly and with integrity. We have zero tolerance for modern slavery, servitude, forced or compulsory labour, child labour, and human trafficking in any part of our business or supply chain.

SmartGenie Ltd is not currently required to publish a statutory modern slavery statement under section 54 of the Modern Slavery Act 2015 because it does not meet the applicable turnover threshold. However, we recognise the importance of transparency and responsible supply chain management and have adopted this voluntary statement as an equivalent policy document for procurement and governance purposes.

This statement sets out the steps SmartGenie Ltd takes, and will continue to take, to reduce the risk of modern slavery and human trafficking in its operations and supply chains.

2. Organisation structure, business and supply chains

SmartGenie Ltd is a UK-based technology company providing AI, cloud, automation, software advisory, implementation and related professional services. Our services may include solution architecture, AI strategy, software development, data processing workflows, cloud deployment, integration, security-aligned design and managed technology services.

SmartGenie Ltd currently operates as a small organisation with a limited direct workforce and a primarily professional-services based operating model. Our supply chain is therefore relatively low complexity and mainly consists of:

• cloud platform providers;
• software and SaaS providers;
• professional services partners and subcontractors;
• independent consultants;
• technology vendors;
• business administration, legal, accounting and insurance service providers.

We do not manufacture physical goods and do not operate labour-intensive production facilities. Where subcontractors or delivery partners are used, SmartGenie Ltd expects them to comply with applicable laws and to conduct their activities ethically and responsibly.

3. Policies in relation to slavery and human trafficking

SmartGenie Ltd has a zero-tolerance approach to modern slavery and human trafficking. We expect all employees, contractors, subcontractors, suppliers and business partners to act in accordance with the following principles:

• no use of forced, bonded, involuntary, trafficked or child labour;
• compliance with applicable employment, immigration, wage and working-time laws;
• fair and respectful treatment of workers;
• no restriction of workers' freedom of movement through coercion, threats, retention of identity documents or unlawful deductions;
• prompt reporting of any suspected modern slavery or unethical labour practice.

SmartGenie Ltd's approach is supported by its wider governance practices, including supplier selection, contractual controls, information security, data protection, procurement due diligence and responsible business conduct.

4. Due diligence processes

SmartGenie Ltd applies proportionate due diligence to suppliers, subcontractors and delivery partners, taking account of the nature of the services provided, geography, sector risk, access to customer data and the criticality of the supplier to service delivery.

Our due diligence activities may include:

• checking supplier identity, location and business legitimacy;
• reviewing supplier reputation, capability and suitability;
• requiring suppliers and subcontractors to comply with applicable laws, including labour, employment and anti-slavery laws;
• considering modern slavery risk when appointing new subcontractors or delivery partners;
• seeking confirmation that key suppliers maintain appropriate ethical, compliance or modern slavery policies where relevant;
• using written agreements, statements of work or purchase terms to define expected standards;
• escalating concerns where supplier conduct may create legal, ethical, delivery or reputational risk.

As SmartGenie Ltd grows, we will continue to improve our supplier onboarding and due diligence processes.

5. Risk assessment and risk management

SmartGenie Ltd considers its overall modern slavery risk to be low because its current business model is based mainly on professional technology services and cloud/software supply chains, rather than labour-intensive manufacturing, warehousing, agriculture, construction or high-volume manual labour.

The areas where some risk may arise include:

• subcontracted professional services where workers are engaged through third parties;
• overseas suppliers or service providers operating in jurisdictions with weaker labour protections;
• low-cost back-office, administrative or support services;
• any future physical goods, hardware or facilities-related procurement.

To manage these risks, SmartGenie Ltd will:

• use reputable suppliers and partners wherever possible;
• apply proportionate checks before appointing subcontractors or delivery partners;
• include compliance expectations in supplier and subcontractor arrangements where appropriate;
• avoid suppliers where there are credible concerns about forced labour, exploitation or unethical working practices;
• investigate any concerns raised by staff, customers, suppliers or other stakeholders;
• take corrective action where issues are identified, including supplier remediation, suspension or termination where appropriate.

6. Measuring effectiveness

SmartGenie Ltd will assess the effectiveness of its approach through proportionate indicators, including:

• no confirmed incidents of modern slavery or human trafficking in our business or supply chain;
• supplier and subcontractor onboarding checks completed where relevant;
• contractual or written expectations communicated to key subcontractors and delivery partners;
• concerns, if any, logged and reviewed;
• appropriate action taken where supplier risks are identified;
• periodic review of this statement as the business grows.

Given the current size and nature of SmartGenie Ltd, these measures are designed to be practical and proportionate. We will mature the framework as our supplier base, workforce and delivery obligations expand.

7. Training and awareness

SmartGenie Ltd will ensure that personnel involved in supplier selection, subcontractor engagement, procurement, delivery governance or customer contract management are aware of modern slavery risks and the company's zero-tolerance position.

Training and awareness may include:

• briefing relevant personnel on the Modern Slavery Act 2015 and supplier risk indicators;
• ensuring delivery leads understand how to escalate concerns;
• including modern slavery considerations in supplier onboarding and procurement discussions;
• refreshing awareness periodically or when the business enters higher-risk markets or supply chains.

8. Reporting concerns

Any employee, contractor, subcontractor, supplier, customer or other stakeholder who has concerns about modern slavery, forced labour, unethical recruitment, child labour or human trafficking connected to SmartGenie Ltd or its supply chain should report the concern promptly to:

• Contact: Sachin Mundra
• Role: Founder / Director
• Email: support@smartgenie.co.uk

SmartGenie Ltd will review concerns seriously, confidentially where appropriate, and take proportionate action.

9. Board approval

This statement has been approved by the Director of SmartGenie Ltd and will be reviewed periodically, or sooner if there is a material change in the business, supply chain, procurement requirements or applicable law.

Signed:

Sachin Mundra

Founder / Director

SmartGenie Ltd