Our Commitment to Ethical Practices

1. Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that DarkStrata Ltd ("we", "us", "our") has taken, and continues to take, to ensure that modern slavery and human trafficking are not taking place within our business or supply chain.

We are committed to acting ethically and with integrity in all our business dealings and relationships. We take a zero-tolerance approach to modern slavery and human trafficking in any form, and are dedicated to implementing and enforcing effective systems and controls to ensure this.

This statement relates to our financial year ending 2025/2026.

2. Our Organisation

DarkStrata Ltd is a software-as-a-service (SaaS) company registered in England and Wales (Company No: 16521338). We provide a cloud-based cybersecurity platform that enables organisations to monitor, detect, and respond to security threats across the dark web and other digital channels.

Our operations are primarily digital in nature. Our workforce consists of skilled technology professionals based predominantly in the United Kingdom. We do not operate manufacturing facilities, warehouses, or physical production sites.

3. Our Supply Chain

As a SaaS business, our supply chain differs from traditional industries. Our principal supply chain categories include:

• Cloud infrastructure providers: Data centres and hosting services that support our platform
• Software and technology vendors: Third-party software, APIs, and development tools integrated into our services
• Professional services: Legal, accounting, and consulting firms that support our operations
• Payment processors: Financial services providers that handle customer transactions
• Office and facilities: Providers of office space, equipment, and related services
• Recruitment and staffing: Agencies and platforms used to source talent

We recognise that whilst the direct risk of modern slavery within a technology supply chain may be lower than in some other sectors, risks can exist further down the chain, particularly in relation to hardware manufacturing, data centre operations, and outsourced services.

4. Our Policies

We operate a number of internal policies to ensure we are conducting business in an ethical and transparent manner. These include:

• Anti-Slavery and Human Trafficking Policy: We maintain a clear policy that sets out our commitment to preventing modern slavery and the responsibilities of all staff
• Recruitment and Employment Policy: We carry out appropriate right-to-work checks for all employees and verify the identity and eligibility of all staff. We ensure that employment terms are fair and transparent, and that all employees are paid at least the National Living Wage
• Whistleblowing Policy: We encourage all employees, contractors, and business partners to report any concerns related to modern slavery or unethical conduct without fear of retaliation
• Supplier Code of Conduct: We expect our suppliers and business partners to uphold the same standards of ethical behaviour, including compliance with all applicable modern slavery legislation

5. Due Diligence

We undertake due diligence when considering new suppliers and regularly review our existing suppliers. Our due diligence processes include:

• Evaluating potential suppliers against modern slavery and human trafficking criteria before onboarding
• Reviewing the modern slavery statements of major suppliers, particularly cloud infrastructure and technology vendors
• Including anti-slavery provisions in contracts with suppliers where appropriate
• Assessing the geographical and sector-specific risks associated with each supplier
• Maintaining an ongoing dialogue with key suppliers regarding their own anti-slavery measures

6. Risk Assessment

We have assessed the risk of modern slavery occurring within our business and supply chain. Given our operating model as a SaaS company, we have identified the following risk areas:

7. Training and Awareness

We are committed to raising awareness of modern slavery issues within our organisation. Our approach includes:

• Ensuring that all staff involved in recruitment and procurement are aware of the indicators of modern slavery and know how to report concerns
• Including modern slavery awareness as part of our onboarding process for new employees
• Providing guidance to relevant staff on how to identify and escalate potential modern slavery risks in our supply chain
• Maintaining open communication channels so that any concerns can be raised promptly and without fear of reprisal

8. Key Performance Indicators

We use the following key performance indicators to measure our effectiveness in ensuring modern slavery is not occurring in our business or supply chain:

• Percentage of key suppliers who have been assessed against modern slavery criteria
• Number of staff who have received modern slavery awareness training
• Number of reports received through our whistleblowing channels related to modern slavery concerns
• Completion rate of due diligence checks on new suppliers

9. Looking Ahead

We are committed to continuously improving our practices to combat modern slavery. In the coming year, we plan to:

• Enhance our supplier assessment process with more detailed modern slavery risk criteria
• Expand training programmes to cover all employees, not just those in procurement and recruitment roles
• Review and strengthen anti-slavery clauses in our standard supplier contracts
• Engage with industry bodies and peers to share best practices for tackling modern slavery in the technology sector

10. Board Approval

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

11. Contact Us

If you have any questions about this statement or wish to report concerns related to modern slavery, please contact us:

Email: hello@darkstrata.io
Website: darkstrata.io

DarkStrata Ltd
Registered in England and Wales
Company No: 16521338
VAT Registration No: GB495674335