Introduction

NCTech is committed to the highest standards of ethical conduct and integrity in our business activities both in the UK and the US. We recognize that modern slavery, which includes slavery, servitude, forced labor, and human trafficking, is a grave violation of fundamental human rights. NCTech has a zero-tolerance approach to modern slavery and is dedicated to ensuring that our business operations and supply chains are free from any form of slavery or human trafficking.

Our Commitment

NCTech pledges to:

• Act Ethically and Transparently: Conduct all business operations with honesty, integrity, and transparency.
• Compliance with Laws: Adhere strictly to all applicable laws and regulations related to modern slavery and human trafficking, including but not limited to the UK Modern Slavery Act 2015 and relevant US legislation.
• Supply Chain Integrity: Implement robust due diligence procedures to identify, assess, and mitigate risks of modern slavery within our supply chain.

Key Actions and Measures

To uphold our commitment, NCTech will undertake the following actions and measures:

1. Risk Assessment and Due Diligence

• Conduct regular risk assessments to identify areas of our business and supply chains where there is a potential risk of modern slavery.
• Implement due diligence processes for new and existing suppliers to ensure they comply with our anti-slavery policy.
• Require suppliers to provide evidence of their own anti-slavery measures and policies.

2. Supplier Code of Conduct

• Develop and enforce a Supplier Code of Conduct that clearly outlines our expectations regarding the prohibition of modern slavery and human trafficking.
• Ensure all suppliers and contractors understand and adhere to our Supplier Code of Conduct.

3. Training and Awareness

• Provide comprehensive training to all employees to raise awareness about modern slavery and human trafficking and inform them of our policy and procedures.
• Ensure that key personnel involved in procurement and supply chain management receive specialized training to recognize and address modern slavery risks.

4. Reporting and Whistleblowing

• Establish a confidential reporting mechanism for employees, suppliers, and other stakeholders to report any concerns related to modern slavery.
• Ensure that all reports are thoroughly investigated, and appropriate actions are taken to address any identified issues.

5. Continuous Improvement

• Regularly review and update our anti-slavery policy and procedures to ensure they remain effective and reflect current best practices.
• Engage with stakeholders, including industry bodies, NGOs, and other organizations, to stay informed about emerging risks and trends related to modern slavery.

Governance

NCTech’s Board of Directors is responsible for overseeing the implementation and effectiveness of this policy. The Board will receive regular reports on compliance and any incidents related to modern slavery.

Conclusion

NCTech is unwavering in its commitment to combat modern slavery and human trafficking. We will continue to work diligently to ensure that our business operations and supply chains are free from any form of exploitation. This policy reflects our dedication to ethical business practices and our responsibility to protect human rights.

Approved by the NCTech Board of Directors

Date: 6/6/2024