Modern Slavery And Human Trafficking Statement

Introduction

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 July 2023.

Nine Tracks Limited (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

Organisational Structure

Nine Tracks Limited has business operations in the United Kingdom.

We operate in the Information Technology sector. The nature of our supply chains is as follows: We work with several key direct suppliers, who provide us with goods, such as computing equipment for our premises and services such IT software, accounting and consulting.

For more information about the Company, please visit our website www.ninetracks.com.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

We have a very small supply chain due to the nature of our work. Where possible we try to collaborate with and partner with larger companies and leading firms, which means we can collectively address exploitation within supply chains. Our key suppliers are:

• Microsoft
• Adobe
• Xero
• Bytes Software
• Superscript

We also work with some SME’s similar to ourselves where we have a strong personal relationship and can be sure of a trusted supply chain in terms of Modern-Day Slavery.

These companies include:

• SO Accounting
• Henley Project management Solutions
• Neon Technologies
• Answer 21 Solutions
• Artemis Cloud

Our due diligence procedures aim to:

• Identify and act on potential risks in our business and supply chains.
• Monitor potential risks in our business and supply chains
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.

Risk and Compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

• Evaluating the slavery and human trafficking risks of each new supplier.
• We do not consider that we operate in a high-risk environment because the majority of our supply chain is based in the UK and in low-risk industries, such as internet software and services.
• We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our procedures by any of our suppliers, we will require that supplier to remedy the non-compliance.

Effectiveness

The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

• We will contact suppliers to enquire about their modern slavery practices every 12 months.
• We will train our staff about modern slavery issues and increase awareness within the Company.

Training Staff

The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The Company’s training covers:

• Recognise what modern slavery and human trafficking are and the scale of the problem.
• Know what signs to look out for.
• Appreciate the key risks to our Company and how we may be implicated.
• Take appropriate action to manage the risks, and tackle modern slavery and human trafficking.

The statement was approved by the board of directors.

Ainsley Bilton, Director
Artur Vogt, Director
Paul Gradidge, Director

Nine Tracks Limited
Date: 21/06/2024