Modern Slavery Statement

AHEAD Modern Slavery Statement

AHEAD’s Statement on the Prevention of Modern Slavery and Human Trafficking

This statement is made pursuant to the UK Modern Slavery Act 2015 and sets out the steps taken by AHEAD, Inc. and its subsidiaries (“AHEAD”) during the financial year ending December 31, 2025, to prevent modern slavery and human trafficking in its business operations and supply chains.

This joint statement is prepared by AHEAD, Inc. on behalf of its wholly owned subsidiaries:

  • AHEAD UK Solutions Limited
  • Ahead DB (India) Private Limited

A joint statement has been prepared because these entities use the same policies and processes,
operate in the same sectors, and have shared suppliers.

AHEAD’s Commitment

AHEAD is committed to conducting business responsibly and ethically across all regions in which we operate. We oppose all forms of modern slavery, servitude, forced labor, child labor, and human trafficking. This Statement outlines the steps AHEAD takes to identify, prevent, and mitigate risks of modern slavery in our operations and supply chain.

Operations

AHEAD considers itself to be low risk with respect to modern slavery practices in its operations. This is based on an assessment of AHEAD’s geographical footprint against the Global Slavery Index’s list of high, medium and low risk countries. AHEAD primarily operates in lower geographic risk countries and regions, including in the United States, United Kingdom, and Europe. AHEAD also operates in India, which is recognized by the Global Slavery Index as above average vulnerability risk.

AHEAD’s workforce is primarily made up of skilled full-time permanent employees, which further supports our low-risk status. AHEAD does, however, engage some contractors, which is addressed further below.

Supply Chain

Our suppliers vary by project and geography from one-off purchases to multi-year, large value strategic relationships governed by master agreements. Given the nature of our business, AHEAD’s supply chain is primarily composed of:

  • Technology hardware and software providers.
  • Professional services subcontractors.
  • Indirect suppliers supporting day-to-day corporate operations, such as office equipment providers, facilities services, and administrative support vendors.

Additionally, AHEAD generally uses placement and recruiting agencies to source independent contractors for its workforce, and these agencies are selected following a standard sourcing process that includes vendor due diligence, background checks, and other compliance processes intended to reduce or eliminate corruption and modern slavery risk. All workers employed by AHEAD are subject to background checks, if allowed under applicable local law.

We expect all suppliers regardless of volume to adhere to applicable laws, including employment laws related to child labor, wages, working hours, and working conditions.

Policies and Governance

AHEAD is committed to operating in an ethical and responsible manner, including maintaining high ethical standards across our business relationships. We have a zero-tolerance approach to any form of human rights abuse, including modern slavery, and are committed to having in place effective systems and controls to prevent any form of modern slavery taking place within our business or supply chain. Relevant policies include:

  • Employee Handbook (including Code of Ethics and Code of Conduct)
  • Vendor Code of Conduct

These policies set out expectations for integrity, lawful employment practices, and ethical behavior across our workforce and supplier base, including prohibitions against force, bonded or compulsory labor, human trafficking or other kinds of slavery.

Risk Assessment and Due Diligence

AHEAD applies a risk-based due diligence process across its supplier lifecycle. This includes identifying and assessing potential risks and taking appropriate action based on the outcome of that assessment. We assess potential risks of unethical labor practices as part of our supplier onboarding and procurement processes. Where appropriate, we review supplier documentation or obtain confirmations through the vendor risk assessment process to assess alignment with our standards.

Key factors that may indicate modern slavery risks that we evaluate include:

  1. The country or region where the supplier operates.
  2. Higher risks are associated with countries identified as having elevated modern slavery occurrences, weak labor law enforcement, or higher vulnerability to forced labor, as indicated by recognized indices (e.g., Global Slavery Index). The industry or sector in which the supplier operates.
    • Higher risks are associated with sectors that rely on low-skilled, temporary, or migrant labor, or involve subcontracting and complex labor supply chains.
  3. The product or service that the supplier provides.
    • Higher risks may be associated with products or services involving hardware procurement, logistics, or installation services, where extended or multi-tier supply chains may be present.
  4. The supplier itself.
    • Some suppliers may have a record of poor practices or human rights violations.

We recognize that some of our suppliers may operate in countries or sectors that have a higher risk of modern slavery. Therefore, we conduct regular risk assessments to identify and prioritize these suppliers based on various criteria, such as the nature of their business, the location of their operations, and the type of workers they employ. We also monitor changes in the global trade environment that may affect the level of risk exposure.

Due diligence activities are conducted at onboarding and on an ongoing basis, with suppliers subject to reassessment based on risk. Where potential risks are identified, AHEAD evaluates the nature of the risk and may determine to proceed with, or to terminate, the business relationship where appropriate.

We are committed to protecting vulnerable populations by ensuring that our suppliers adhere to strict ethical standards and labor practices.

This risk-based approach enables us to focus on critical areas.

Training and Awareness

AHEAD values training as it is the best way to prevent risks and raise awareness on ethical topics. Each year AHEAD conducts a mandatory compliance training campaign for all employees that reinforces expectations for lawful business conduct and emphasizes employees’ obligations to report concerns. Training content is periodically reviewed to ensure it continues to support AHEAD’s governance and risk management objectives.

Whistleblowing

AHEAD maintains a reporting mechanism that enables employees to raise concerns related to unethical conduct, including potential human rights violations, anonymously through a third-party managed whistleblowing system or through internal channels such as management, People & Culture, or Legal.

AHEAD prohibits retaliation against individuals who report concerns in good faith and is committed to ensuring that all reports are reviewed and addressed appropriately.

2026 Outlook

We are dedicated to continuously improving our practices and ensuring that this Statement remains current and effective. As part of this commitment, we will regularly review and update the Statement on an ongoing basis to reflect any changes in legislation, risk factors, or business practices.

In this financial year we will build upon what we already have in place by:

  • Confirming the risk profile of every important vendor and having a plan for each high-risk
    vendor to move away from them as soon as possible if they continue to be high risk.

Approval

This Statement fulfils the requirements of applicable laws concerning modern slavery and covers the financial year from 1 January 2025 to 31 December 2025. AHEAD’s executive leadership team has reviewed and approved this Statement and has confirmed that the information is accurate as of that date.

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