Anti-Slavery & Human Trafficking Policy
Effective date: January 1, 2026 · Last reviewed: July 2026 · Applies globally
1. Policy Statement
Ctrl ("the Company") has a zero-tolerance approach to modern slavery, forced labour, child labour, servitude, and human trafficking in any form, in any part of our business or supply chains. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own operations or those of our suppliers, partners, and contractors.
This policy is drafted to meet or exceed the requirements of the United Kingdom, the United States, and Canada, and applies to all persons working for or on behalf of the Company in any capacity, including employees, directors, officers, agency workers, contractors, consultants, and business partners.
2. United Kingdom — Modern Slavery Act 2015
2.1 Statement under Section 54
This section constitutes the Company's slavery and human trafficking statement pursuant to Section 54 (Transparency in Supply Chains) of the UK Modern Slavery Act 2015. Where the Company meets the statutory turnover threshold, this statement will be approved by the board of directors, signed by a director, and published prominently on the Company's website annually within six months of the financial year end.
2.2 Our Business & Supply Chains
Ctrl provides geospatial intelligence, robotics-as-a-service, drone data capture, and operational software. Our supply chains include hardware manufacturers (drones, docks, sensors), cloud and data infrastructure providers, logistics carriers, field service contractors, and professional services.
2.3 Due Diligence & Risk Assessment
- We map our supply chain tiers and assess slavery and trafficking risk by category, geography, and workforce profile.
- Higher-risk suppliers (e.g., electronics component manufacturing, logistics) undergo enhanced screening and contractual commitments.
- Supplier contracts include anti-slavery warranties and audit rights, with termination rights for breach.
- We do not use recruitment fees charged to workers anywhere in our operations, and require the same of suppliers (Employer Pays Principle).
2.4 Key Performance Indicators
- Percentage of tier-1 suppliers that have signed our Supplier Code of Conduct.
- Number of supplier risk assessments and audits completed annually.
- Number of modern slavery concerns reported and resolved.
- Percentage of relevant staff completing modern slavery awareness training.
3. United States — Federal & State Requirements
3.1 Federal Compliance
The Company complies with the Trafficking Victims Protection Act (TVPA), the Tariff Act of 1930 (Section 307, prohibiting import of goods made with forced labour, as enforced by U.S. Customs and Border Protection), and the Uyghur Forced Labor Prevention Act (UFLPA). Where the Company acts as a U.S. federal contractor or subcontractor, it complies with FAR 52.222-50 (Combating Trafficking in Persons), including the prohibition on:
- Engaging in severe forms of trafficking in persons or procuring commercial sex acts.
- Using forced labour in the performance of any contract.
- Destroying, concealing, or confiscating employee identity or immigration documents.
- Using misleading or fraudulent recruitment practices, or charging employees recruitment fees.
- Failing to provide return transportation where required at the end of employment.
3.2 California Transparency in Supply Chains Act (SB 657)
To the extent applicable, the Company discloses its efforts to eradicate slavery and human trafficking from its direct supply chain, covering: (a) verification of product supply chains to evaluate risks; (b) supplier audits; (c) supplier certification that materials comply with slavery and trafficking laws of the countries in which they do business; (d) internal accountability standards; and (e) employee and management training.
3.3 Reporting & Enforcement
Suspected violations involving U.S. operations may be reported internally (Section 6) or to the Global Human Trafficking Hotline. The Company will cooperate fully with enforcement agencies, including CBP withhold-release order inquiries.
4. Canada — Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211)
4.1 Annual Report
Where the Company meets the reporting entity thresholds under Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (in force January 1, 2024), it will file an annual report with the Minister of Public Safety by May 31 each year and publish it prominently on its website. The report addresses:
- The Company's structure, activities, and supply chains.
- Policies and due-diligence processes in relation to forced labour and child labour.
- The parts of the business and supply chains that carry a risk of forced labour or child labour, and steps taken to assess and manage that risk.
- Measures taken to remediate any forced labour or child labour, and remediation of loss of income to vulnerable families.
- Training provided to employees on forced labour and child labour.
- How the Company assesses its effectiveness in ensuring forced and child labour are not used.
4.2 Customs Tariff Prohibition
The Company complies with the Canadian Customs Tariff prohibition on importing goods mined, manufactured, or produced wholly or in part by forced labour or child labour, and screens hardware and component imports accordingly.
5. Responsibilities
- Board / Leadership: overall responsibility for this policy, annual review, and approval of statutory statements.
- Operations & Procurement: embedding anti-slavery requirements in supplier selection, onboarding, and contracts.
- All personnel: reading, understanding, and complying with this policy; reporting concerns promptly.
- Suppliers & partners: certifying compliance, permitting audits, and flowing requirements down to their own supply chains.
6. Reporting Concerns & Whistleblower Protection
Anyone may raise a concern about slavery, trafficking, forced labour, or child labour — in confidence and without fear of retaliation — through the Company contact form or directly to leadership. Reports may be made anonymously. The Company prohibits retaliation against anyone who reports a concern in good faith, consistent with UK whistleblowing protections, U.S. whistleblower statutes, and Canadian employment law.
7. Breach, Remediation & Training
Breach of this policy by an employee may result in disciplinary action up to and including termination. Breach by a supplier or partner may result in suspension or termination of the relationship. Where forced or child labour is identified, the Company will prioritise remediation for affected workers over termination of contracts where remediation is achievable. Relevant staff receive training on identifying and reporting modern slavery risk.