Modern Slavery Statement

1. Introduction

This Modern Slavery Statement sets out the steps taken by Shelftrak Ltd ("we", "our", "us") to prevent modern slavery and human trafficking in our business operations and supply chains. We are committed to ensuring that slavery, servitude, forced labour, and human trafficking have no place in our business or among those who work with us.

2. Our Business

Shelftrak Ltd is a commercial technology company that provides AI-powered retail execution tracking and category insight services to global brands and retailers. Our services include:

• A Global Tracking Service monitoring execution in airports and stores across multiple countries.
• Shelfcheck App – enabling real-time in-store data capture via field teams and retailers.
• Bespoke consultancy and data reporting services.

We operate globally with clients and suppliers in the UK, Europe, the Middle East, Asia, and the USA.

3. Our Supply Chain

Our supply chain includes:

• Freelance data collectors and image capture teams
• Technology and AI partners based in the UK
• Offshore contractors and data teams (e.g. India, UAE)
• Cloud service providers and software platforms

We maintain a close relationship with our suppliers and partners and expect all parties we work with to share our commitment to ethical and fair practices.

4. Policies and Commitments

We are committed to acting with integrity in all our relationships. Our internal policies and practices include:

• Ethical Code of Conduct for employees, contractors, and suppliers
• Supplier Due Diligence processes to assess labour practices
• Clear terms and contracts that require legal and ethical compliance
• Ongoing monitoring of overseas data processing and collection partners

5. Risk Assessment

We recognise that some elements of our business may carry a higher risk of modern slavery, particularly in:

• Outsourced or offshore data collection services
• Use of temporary or contract labour
• Geographic regions where labour protections are weaker

We actively assess these risks through regular supplier engagement, contract reviews, and transparency requirements.

6. Due Diligence and Training

• All suppliers are subject to a review process to ensure compliance with ethical labour standards.
• Contractual agreements include requirements to comply with the UK Modern Slavery Act (where applicable) and international labour laws.
• Shelftrak Ltd staff responsible for procurement and supplier relationships receive training on modern slavery awareness.

7. Looking Ahead

Over the next 12 months, we aim to:

• Formalise a Supplier Code of Conduct
• Introduce annual supplier self-assessments related to modern slavery
• Expand training for internal teams on supply chain vigilance

8. Approval

This statement has been approved by the Directors of Shelftrak Ltd and will be reviewed annually.

Signed:
Managing Director
Shelftrak Ltd
Date: March 2025
Registered Address: 3 & 4 Park Court, Riccall Road, Escrick, York, YO19 6ED
Company No: 16272009