Modern Slavery Statement

1. Introduction

Pursuant to the UK Modern Slavery Act 2015, this statement is made for and on behalf of the Company and its subsidiaries for the fiscal year ending on 31 January 2025. The Company is committed to conducting its business in accordance with the highest ethical standards of conduct and continued respect for human rights.

The Company is fully committed to preventing slavery and human trafficking at all levels of its operations and supply chains. This statement addresses the steps the Company takes to identify potential risks related to its business and to prevent modern slavery in its supply chains.

2. Modern Slavery Statement

The Company is committed to operating its business in a legal and socially responsible manner and has fully committed to prevent slavery and human trafficking. As of the date above, the Company is not aware of any allegations of human trafficking or slavery activities against any of its current suppliers. In the event such allegations arise, we will immediately conduct an investigation and will report such allegations or investigation results to the relevant authorities where required.

3. Employee Culture

Company employees and contractors are expected to be familiar with, and adhere to, our Employee Code of Conduct and Business Ethics (the “Code ”). The Code describes our core values and establishes standards for how we work with each other, our customers and our partners. Our business is conducted in accordance with these guiding principles and fosters a culture of ethics and trust. The Company encourages its employees to report any violations of labor and employment law or violations of our Code to our trained People T eam personnel without fear of reprisal.

4. Controls

The Company is committed to acting with integrity in all activities and has adopted various policies and/or has implemented employee training on the following relevant topics:

• Code of Conduct;
• Conflicts of Interest;
• Confidentiality;
• Foreign Corrupt Practices Act (“FCPA ”);
• Anti-Bribery and Anti-Corruption; and
• Global Harassment and DiscriminationDocusign Envelope ID: C0E0AC77-47DA-458E-A7F9-C3F60740724A

5. Supply Chain

We expect our suppliers to attest to adhering to all applicable laws and regulations. W e do not tolerate slavery and human trafficking within our supply chain and would seek to terminate our relationship with a supplier where evidence of the same was reported.

While we believe that we work in a sector and territories where modern slavery and human trafficking are particularly low risk, every company is at risk of being involved in some way through its operations and supply chain. We want to work with suppliers who are aligned with our values and we are committed to ensuring that there is no slavery or human trafficking arising in any part of our business or in relation to those with whom we conduct business.

6. Risk Assessment

We have developed standards, processes and procedures including:

• The ongoing monitoring and review of the effectiveness of our internal policies and their implementation;
• Supplier due diligence on an as-needed basis;
• Policies supporting an inclusive, open and tolerant workplace environment; and
• Procedures for raising concerns by our employees.

This Modern Slavery Statement was approved by the authorized representatives of Adzerk, Inc. as of November 21,2024

Signed for and on behalf of Adzerk, Inc.