Modern Slavery Act and Human Trafficking Statement

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Introduction

This statement has been produced in accordance with the Modern Slavery Act 2015 under UK law in relation to the financial year ending December 31, 2023. Nuvolo Inc. (collectively referred to as Nuvolo) is a global company with operations in over four countries and hundreds of employees. We are committed to acting ethically, with integrity, and promoting work environments that engender conditions of freedom, equality, security, and dignity. Nuvolo expects its employees, contractors, and suppliers to prevent acts of modern slavery and human trafficking from occurring within both its business and supply chains, which have policies and codes of conduct (including the Employee Code of Conduct and the Vendor Compliance Program) in place to establish standards expected across our business activities. Our governance framework and related corporate policies empower our employees and contractors to report and escalate any concerns of unethical conduct, whether relating to modern slavery, human trafficking or other matters. Nuvolo has a zero-tolerance approach to Modern Slavery. All members of our staff are expected to report any concerns, however small they may seem, which will be investigated and, where appropriate, acted upon.

Our business and supply chains

Nuvolo with offices in the United States, India, Bulgaria, and the United Kingdom. In terms of our supply chains, we engage highly skilled and specialist suppliers to support our products and services.

Our Modern Slavery policies and controls

We operate the following policies and controls to prevent Modern Slavery within our business and supply chains:

• Recruitment policy – we use only specified and reputable employment agencies to source labor and always verify the practices of any new agency before accepting workers from that agency.
• Whistleblowing policy – we encourage all members of our staff to report any concerns related to the direct activities, or the supply chains of, our business. Our whistleblowing procedure is designed to encourage and make it easy for members of staff to make disclosures, without fear of retaliation. All disclosures will be fully investigated, and appropriate remedial action will be taken.
• Employee code of conduct – this code clarifies to employees the actions and behavior expected of them when representing our business. We strive to maintain the highest standards of employee conduct and ethical behavior when operating abroad and managing our supply chain.
• Supplier/Procurement – we vet all our suppliers before we do business with them. We only engage well-established and reputable suppliers who share our commitment to acting ethically and with integrity.
• Staff training – we provide training to our staff to ensure that they understand and are fully aware of the above policies and controls, including our zero-tolerance approach.

Our assessment of the risk of Modern Slavery and ongoing initiatives

We consider that the overall risk of exposure within our business and supply chains to Modern Slavery is low, particularly given: the highly skilled nature of the work undertaken by our staff and suppliers, our industry sector, and the jurisdictions in which we do business.

Nonetheless, we acknowledge our responsibility to remain alert to the risks, which are not static and are committed to ongoing and proactive efforts to ensure that our policies and controls remain effective. We, therefore, commit to the following initiatives:

• Continue to build upon initiatives to raise awareness levels of our staff;
• Review staff training programs and levels of staff training; and
• Continue to build upon supplier checks, due diligence, and auditing processes

Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Nuvolo’s modern slavery and human trafficking statement for the financial year ending December 31, 2023. It has been approved by Nuvolo, Inc. Chief Operating Officer.