Modern Slavery Statement

1. Introduction

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Vitalytics' slavery and human trafficking statement for the financial year ending December 2024.

Vitalytics is committed to preventing slavery and human trafficking in our corporate activities and to ensuring that our supply chains are free from slavery and human trafficking.

2. Our Business and Supply Chains

Vitalytics is a global managed IT services provider specializing in:

• Azure Cloud Solutions
• OpenStack Implementation
• Server Management and Infrastructure
• Workstation Support
• Network Management
• Cybersecurity Services

We operate across multiple countries including the United Kingdom, United States, Switzerland, Germany, Norway, UAE, and Australia.

2.1 Our Supply Chain

Our supply chain includes:

• Technology hardware and software suppliers
• Cloud infrastructure providers (Microsoft Azure, OpenStack)
• Network equipment manufacturers
• Professional services contractors
• Facility management and office services

3. Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We have implemented the following policies to reflect our commitment:

3.2 Recruitment and Employment

We ensure all employees are legally entitled to work in their respective countries and are paid at least the national minimum wage or living wage where applicable. We do not use forced, compulsory, or trafficked labor.

3.3 Supplier Standards

We expect our suppliers to maintain the highest standards of ethics. Our supplier contracts include specific provisions requiring compliance with the Modern Slavery Act 2015.

4. Due Diligence Processes

We have implemented the following due diligence processes to identify and mitigate risk:

4.1 Supplier Assessment

• Risk assessment of new suppliers before engagement
• Review of supplier labor practices and working conditions
• Requirement for suppliers to demonstrate their compliance with modern slavery legislation
• Regular audits of high-risk suppliers

4.2 Internal Processes

• Regular review of our recruitment and employment processes
• Verification of right to work documentation
• Monitoring of working conditions and employee welfare
• Anonymous whistleblowing procedures for employees to report concerns

5. Risk Assessment

We have assessed the risks of modern slavery and human trafficking in our business and supply chains. Our assessment indicates that the IT services sector has relatively low direct risk, but we recognize potential risks in:

• Hardware manufacturing supply chains
• International contractor arrangements
• Facilities and cleaning services
• Third-party data centers

We continue to monitor these areas closely and engage with our partners to ensure compliance.

6. Training and Awareness

We provide training to our employees to ensure they understand the risks of modern slavery and human trafficking in our business and supply chains. Training includes:

• Understanding the Modern Slavery Act 2015
• Recognizing signs of modern slavery and human trafficking
• Reporting procedures for suspected cases
• Supplier engagement best practices

7. Measuring Effectiveness

We measure the effectiveness of our efforts to ensure that slavery and human trafficking is not taking place in our business or supply chains through:

• Regular supplier audits and assessments
• Employee training completion rates
• Number of reported concerns and investigation outcomes
• Supplier compliance verification
• Annual review of our modern slavery risks

8. Our Commitment

9. Reporting Concerns

If you have concerns about potential modern slavery or human trafficking in our business or supply chains, please contact us:

10. Approval

This statement has been approved by the Board of Directors of Vitalytics.

Vitliyan Vitliyanov
Founder & CEO
Vitalytics
December 2024