Modern Slavery Policy Statement

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Netwatch Global have taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Our Business

NetWatch specialise in providing powerful and actionable intelligence which our clients either rely on to make effective risk-based decisions or use as evidence. Driven by our market-leading focus on social media investigating, we specialise in providing OSINT investigation software, data, and investigative services.

What is Modern Slavery?

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Netwatch Global has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Scope of this Policy

This policy applies to all persons working for or on behalf of NetWatch Global, including:

• Employees at all levels
• Directors and officers
• Agency workers, seconded workers, and contractors
• Volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

Responsibilities and Training

Management at all levels is responsible for ensuring that those reporting to them understand and comply with this policy. Management will also ensure that employees receive adequate and regular training on this policy and the issue of modern slavery in supply chains.

The CEO has overall responsibility for ensuring that this policy complies with our legal and ethical obligations and is adhered to by all persons working for and on behalf of NetWatch Global.

The HR Business Partner has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Employee Compliance and Reporting

All employees must read, understand, and comply with this policy. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of everyone working for or on behalf of NetWatch Global.

• Immediately report any suspected or potential modern slavery in our business or supply chains at all tiers to senior management, or through our Whistleblowing Policy, if you believe a policy conflict has occurred or may occur.

• If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with senior management promptly.

Any concerns you raise will be handled confidentially, and you can be assured that there will be no negative consequences for reporting in good faith. Senior management will conduct an initial assessment of any concerns and initiate investigation where required.

Supplier Due Diligence

Before entering into business relationships, NetWatch Global conducts thorough due diligence on all suppliers including:

• Online search to ensure that the supplier has not been convicted of modern slavery offenses.
• On-site audits where appropriate to reviewing working conditions and ensure compliance with our standards.

Training and Awareness

We conduct in-house training for our staff so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

Conclusion

We are committed to preventing modern slavery and human trafficking in all forms. This policy ensures that Netwatch Global remains vigilant and proactive in safeguarding against modern slavery in our operations and across our supply chains.