Modern Slavery and Human Trafficking Policy

1. Introduction

Attercop is committed to high standards of ethics, integrity and professional conduct in every aspect of our work. We oppose all forms of modern slavery, forced labour and human trafficking, and we take active steps to prevent these risks within our business operations and supply chains.

This policy sets out our approach to identifying and managing modern slavery risks. It applies to all employees, contractors, partners and suppliers working with or on behalf of Attercop.

2. Our Business

Attercop is a specialist artificial intelligence consultancy headquartered in the United Kingdom. We provide strategic advisory services and technical AI implementation services to organisations across the UK and Europe. Our work is knowledge based, delivered by highly skilled professionals, and does not involve the use of vulnerable labour or high-risk sectors.

Our supply chain primarily comprises professional services providers, software vendors, cloud platforms, and independent contractors.

3. Our Commitment

We are committed to:

• Preventing modern slavery and human trafficking in our operations and supply chains.
• Acting ethically and with integrity in our business relationships.
• Implementing and improving systems and controls to identify and mitigate modern slavery risks.
• Complying with all applicable UK laws and internationally recognised human rights standards.

4. Governance and Responsibilities

Overall responsibility for this policy lies with the CEO. Operational oversight is provided through our internal governance processes.

All employees, associates and contractors are required to:

• Read and understand this policy.
• Report concerns about modern slavery or unethical labour practices in any part of Attercop or our supply chain.
• Cooperate with any investigations relating to modern slavery concerns.

5. Supplier and Partner Due Diligence

We maintain a proportionate risk-based approach to supplier onboarding and review. This includes:

• Assessing suppliers for potential modern slavery risks where relevant.
• Prioritising suppliers with clear ethical and labour standards.
• Including contractual clauses relating to compliance with anti-slavery legislation where appropriate.
• Reviewing relationships with any supplier that fails to meet expected standards.

Given the nature of our business, our supply chain is assessed as low risk. Nonetheless, we expect all suppliers to uphold ethical labour practices and to ensure compliance throughout their own subcontractors.

6. Risk Assessment

Our operations do not involve manufacturing, logistics or low-wage labour environments typically associated with higher levels of modern slavery risk. However, we recognise:

• Some technology or research suppliers may use overseas subcontractors.
• Temporary labour providers can present risk if not properly vetted.
• Rapid scaling in project delivery may occasionally involve new contractors.

We therefore monitor risk areas on an ongoing basis and maintain appropriate controls.

7. Training and Awareness

We provide awareness materials to employees and contractors so they understand:

• The indicators of modern slavery.
• Reporting mechanisms for concerns.
• Our expectations of ethical behaviour in supplier and contractor engagement.

8. Reporting Concerns

Anyone working with or for Attercop can raise concerns about modern slavery or unethical practices. Reports may be made confidentially and without fear of retaliation. We will investigate all concerns promptly and take appropriate corrective action.

9. Policy Review

This policy is reviewed annually to ensure it remains effective and aligned with current legislation and best practice.