1 February 2026 to 31 January 2027
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 2026 to 31 January 2027.
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 and services.
- Mitratech has offices in the United States, United Kingdom, India and Australia, with much 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.
- Responsibility for implementing and monitoring anti-human trafficking initiatives rests with our Legal, HR, and Compliance and Risks departments.
Our Supply Chains and Relationships
We acknowledge that risks of modern slavery can exist within our supply chains, particularly in areas such as use of contract labor.
We are committed to building strong, transparent relationships with our suppliers and contractors. We strive to work with partners who share our values and commitment to ethical labor practices.
Risk Assessment
Mitratech maintains on-going due diligence of its material suppliers to assess whether any 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 and to assess compliance with our standards.
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; and>
- protect the safety and anonymity of whistle blowers.
We also maintain several 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 way we behave as an organisation and how we expect our employees and suppliers to act.
Due Diligence and Performance Indicators
We are committed to ongoing due diligence to identify, prevent, and mitigate any risks of unethical labor practices in our operations and supply chains. Our due diligence processes include:
- gathering information from suppliers about their labor practices and policies via supplier questionnaires; and
- reviewing any relevant certifications held by our suppliers as part of our due diligence process.
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 via reports we may receive from employees, suppliers, public or law enforcement agencies, or other third parties that indicate unethical labor practices, including modern slavery and human trafficking concerns and/or violations.
Ongoing Steps
Having successfully established a foundation for tracking supplier compliance, we are now implementing the following strategic initiatives during the current period:
- We are building a framework for the lifecycle management of third-party partners, focusing on enhanced ‘Know Your Counterparty’ (KYC) protocols.
- We are transitioning to a more centralized structure for tracking and managing partner documentation.
- We will continue to engage with our partners and investors to share cross-industry intelligence on identifying hidden risks within software development and cloud hosting supply chains.
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 2026 to 31 January 2027.
This statement has been approved by Mitratech Holdings, Inc.’s board of directors, who will review and update it annually.
Mike Williams
CEO
1 February 2026
