Modern Slavery Statement

This statement is made in line with the principles of section 54 of the Modern Slavery Act 2015. It sets out the steps Astuco Ltd has taken, and continues to take, to ensure that modern slavery and human trafficking are not taking place within our business or our supply chains. It covers Astuco's financial year ending 28 February 2026.

Astuco has a zero-tolerance approach to modern slavery in all its forms, including forced or compulsory labour, servitude, debt bondage and human trafficking. We are committed to acting ethically and with integrity in all our business relationships.

Our organisation

Astuco is a specialist Small and Medium Enterprise of approximately 15 people providing communications and information systems consultancy, secure infrastructure engineering and technical staffing, principally to UK Defence customers. We operate a remote-first model from the United Kingdom, with no overseas operations. Our people are directly employed or engaged as security-cleared associate contractors under UK contracts.

Our supply chains

Astuco's supply chain is people and expertise rather than physical goods. It consists principally of:

• Our workforce - directly employed staff and vetted associate contractors engaged to deliver services to our customers.
• Professional and digital services - cloud hosting, software licensing and professional advisers, predominantly established UK- and EU-based providers.
• Limited indirect procurement - a small volume of IT equipment and business services for our own operations.

We procure no significant volume of physical goods, raw materials or overseas manufactured product, which materially limits our exposure to the sectors most commonly associated with modern slavery. We assess our recruitment and contingent-labour supply chain as the area warranting the most attention.

Our policies

Astuco maintains a governance framework designed to uphold ethical conduct and protect the people who work for and with us. Relevant policies include our anti-slavery and human trafficking commitment, recruitment and right-to-work verification, whistleblowing, equality and diversity, code of conduct, and our ESG and Sustainable Procurement Policy. These policies are reviewed as part of the integrated management system work under way alongside our ISO 9001 and ISO 27001 activities.

Due diligence and controls

The following controls are in effect and are applied when performing contracts:

• Right-to-work verification. We verify the identity and legal right to work of every individual we employ or engage before they begin work.
• Security vetting. Personnel working on our customers' programmes are subject to formal UK national security vetting (for example BPSS and Security Check), which provides an additional, independent layer of identity and employment verification.
• Direct engagement and fair pay. Our people are engaged under transparent UK contracts and paid at or above statutory minimums, reducing the exploitation risks associated with opaque, multi-tier labour arrangements.
• Trusted recruitment channels. Where we use recruitment partners, we work with established, reputable agencies and expect them to uphold equivalent standards.
• Supplier expectations. Environmental, social and ethical criteria - including modern slavery compliance - form part of our supplier and procurement approval, and we will request modern slavery assurances from suppliers where proportionate to the risk.

Risk assessment

Given our UK-based operations, professional and security-cleared workforce, direct engagement model and minimal physical supply chain, we assess Astuco's inherent modern slavery risk as low. We keep this assessment under review as the business grows and as our supplier and associate base changes.

Training and awareness

Astuco raises awareness of modern slavery risks and indicators among staff involved in recruitment, engagement of associates and procurement, so that they are able to recognise and escalate concerns. Any concern can be raised confidentially under our whistleblowing arrangements without fear of reprisal.

Measuring effectiveness

We monitor the effectiveness of these measures through indicators including completion of right-to-work and vetting checks for all personnel, the absence of any reported or suspected incidents of modern slavery, and the incorporation of modern slavery considerations into supplier onboarding. No incidents of modern slavery were identified during the reporting period.

Approval

This statement has been reviewed and approved by the board of directors of Astuco Ltd. It will be reviewed and updated annually.