This statement sets out the steps that Mitratech Holdings, Inc. (“Mitratech”) has taken and is continuing to take to ensure that modern slavery and human trafficking is not taking place within our business or supply chain. This statement relates to the period 1 February 2024 to 31 January 2025.

Mitratech has a zero tolerance approach to any form of modern slavery, including servitude, human trafficking and forced labour. 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 modern slavery within our business and supply chain.

Our Business

This statement covers the activities of Mitratech and its subsidiary companies (as defined under the Companies Act 2006):

  • Mitratech is a global technology partner for corporate legal departments, risk and compliance teams, and HR professionals. Mitratech designs, develops, delivers, and supports legal, risk management, and HR software solutions.
  • Mitratech has offices in the United States, United Kingdom, India and Australia, with the majority of our business conducted within the United States. Our contractors and suppliers are primarily based within the United States and United Kingdom.
  • Products, services, and software development are generally provided in-house by Mitratech, rather than by third parties.

Risk Assessment

Mitratech maintains on-going due-diligence of its material suppliers to assess whether any particular risks of slavery or human trafficking within its supply chains or any part of our business. We have zero tolerance on slavery and human trafficking. We evaluate our relationships with professional or business services suppliers, such as those who provide hosting support services to identify any potential risks. In part, we manage this risk through the use of suppliers whom are considered to be reputable, and we ensure material regular suppliers confirm that their own business activities and supply chain do not involve slavery or human trafficking.

Our Policies

We have in place systems to:

    • Identify and assess potential risk areas in our supply chains.
    • Mitigate the risk of slavery and human trafficking occurring in our supply chains.
    • Monitor potential risk areas in our supply chains.
    • Protect whistle blowers.

We also operate a number of internal policies to ensure we conduct business in an ethical and transparent manner. We periodically review and update all our policies. These include:

  • Corporate Social Responsibility Policy. This policy set out our commitment to promoting equal human rights for all, as well as monitoring the social, economic, and environmental impacts of our business.
  • Anti-Bribery and Corruption Policy. This policy underpins our commitment to maintaining high standards of ethics, morality and legality in all areas where our business is carried out.
  • Recruitment policy. We conduct eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
  • Whistleblowing policy. We operate a whistleblowing policy so that all employees, without fear of reprisals, can raise concerns about inappropriate behaviour and practices across our business or supply chain.
  • Employee handbook. This handbook explains our code of conduct; the manner in which we behave as an organisation and how we expect our employees and suppliers to act.

Our Performance Indicators

We evaluate the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain (i) by monitoring how we and our suppliers perform against our standards and policies and (ii) if no reports are received from employees, suppliers, the public or law enforcement agencies to indicate that modern slavery practices have been identified. In the prior year, we have not been made aware of through our due diligence and have received no reports from employees, suppliers, the public or law enforcement agencies of alleged modern slavery practices within our business or supply chain.

Ongoing Steps

(A) Further mapping out our supply chain and supplier due diligence to include questionnaires covering modern slavery and developing a Vendor Code of Conduct that requires vendors to comply with applicable law regarding slavery and human trafficking.

(B) Continuous training opportunities to our employees, including senior management and/or contractors. Ensure that our suppliers and business partners provide training to their employees and suppliers and providers.

Board Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Mitratech’s statement for the period 1 February 2024 to 31 January 2025.

This statement has been approved by Mitratech Holdings, Inc.’s board of directors, who will review and update it annually.

Mike Williams CEO
15 March 2024