Modern Slavery Policy

MODULAR DATA LIMITED 

Dated June 2026

Modular Data Ltd 

1. Purpose 

1.1. Our business, Modular Data Limited, is committed to combatting slavery and human trafficking in its business and supply chains, and we make this statement to assist with compliance with the Modern Slavery Act 2015. This statement relates to the financial year ending 31^st March 2026.

1.2. As our business has a turnover of less than £36 million, we do not have a legal obligation to  produce a modern slavery statement. However: 

1.2.1. We agree that exploitation within all supply chains ending in the UK is a blight on our society, and we are committed to playing our part in eliminating exploitation; 

1.2.2. We understand that customers with obligations under the Modern Slavery Act 2015  cannot comply with those duties without our cooperation.  

2. Statement 

2.1. To that end, we confirm that we have examined our own business and, to the extent that it is reasonably practicable, businesses within our supply chain and we confirm the following:  

2.1.1. We confirm that within our own business, no relevant offence relating to slavery or  human tracking has been committed.  

2.1.2. We have made enquiries of businesses that supply directly to us and we are confident that no relevant offence is committed in that business.  

2.2. Insofar as it was reasonably practicable, we have examined our supply chains and confirm that  we found no evidence of slavery or human trafficking. 

3. Scope 

3.1. Modular Data Limited provides consultancy and software development services for enterprises  and organisations within the United Kingdom and Europe. 

3.2. Our business : 

3.2.1. Has 4 full-time employees, 2 directors and engages with 2 business contractors within the UK, which are subject to due diligence reviews

3.2.2. Has 10 or more limited company subcontractor organisations in the UK; which are all subject to due diligence reviews.

3.2.3. Outside EEA: Has 1 subcontractor organisation in Slovakia engaging a larger team of individuals working on software development in Ukraine. We recognise that Ukraine is currently a heightened-risk jurisdiction for labour exploitation due to the ongoing conflict, and we have increased the frequency and depth of our due diligence on this relationship accordingly, including annual review of working conditions, payment practices, and treatment of individuals engaged. Has 1 subcontracted business consultancy based in Hong Kong

3.3. We operate in the United Kingdom and the European Union.

3.4. We understand that certain industry sectors and geographical regions entail greater risk of exploitation than others. In particular, we recognise that our subcontracted operations in Ukraine carry a heightened risk profile due to the ongoing conflict in the region, and we have implemented enhanced due diligence measures for this relationship as a result, including more frequent review and direct engagement on working conditions. We do not believe that any other part of our supply chain is in a heightened-risk sector or region.

3.5. Where it is reasonably practicable, we ensure that businesses in our supply chain have made a  similar statement relating to slavery and human trafficking. 

3.6. The person in our business responsible for assessing matters relating to slavery and human trafficking is: Finbarr Murphy, Chief Executive Officer (CEO).

4. How we raise a concern 

4.1. We encourage all employees to report on any matters relating to slavery or human trafficking  in our supply chains of which they become aware. 

4.2. We encourage all employees and organisations in our supply chains to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If employees have any other queries or concerns, these should be raised with the CEO. 

5. Who is responsible for the policy ? 

5.1. The CEO has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.  

5.2. The operations manager has primary and day-to-day responsibility for implementing this policy,  and for monitoring its use and effectiveness and dealing with any queries on its interpretation. 

5.3. Management at all levels are responsible for ensuring those reporting to them are made aware  of and understand this policy and are given adequate and regular training on it. 

6. Monitoring and review 

6.1. The operations manager will monitor the effectiveness and review the implementation of this  policy, regularly considering its suitability, adequacy and effectiveness. Any improvements  identified will be made as soon as possible. Internal control systems and procedures will be  subject to regular audits to provide assurance that they are effective in countering bribery and  corruption. 

6.2. All staff are responsible for the success of this policy and should ensure they use it to disclose  any suspected danger or wrongdoing.

6.3. Staff are invited to comment on this policy and suggest ways in which it can be improved. Staff
should make suggestions to the operations manager.

6.4. This policy does not form part of any employee’s contract of employment and it may be  amended at any time.