Modern Slavery and Human Trafficking Statement

Maytech Communications Ltd and Kiteworks Europe AG

Financial Year: 2025

Board of Directors Approval

This joint Modern Slavery and Human Trafficking Statement outlines the steps taken by Maytech Communications Ltd and Kiteworks Europe AG (together referred to as “the Companies”) to actively prevent modern slavery and human trafficking within their operations and supply chains. The Director of Kiteworks Europe AG, the parent company, has reviewed and formally approved this statement.

Introduction

The Companies acknowledge the importance of providing decent working conditions and protecting human rights. We are committed to ensuring that all forms of modern slavery, including forced labor, servitude, compulsory labor, and human trafficking, are strictly prohibited in our business activities and throughout our supply chains.

Structure, Business Operations, and Supply Chains

Maytech Communications Ltd specializes in secure managed file transfer services for clients within the United Kingdom. Kiteworks Europe AG delivers secure content communication solutions to both public and private sector clients across Europe.

Our supply chains are primarily composed of digital service providers, such as cloud infrastructure partners, data center operators, cybersecurity experts, software developers, professional service firms, and telecommunications partners. Neither Maytech Communications Ltd nor Kiteworks Europe AG is involved in hardware manufacturing or labor-intensive production, which typically carry higher risks related to modern slavery.

Governance and Human Rights Policies

The Companies have established governance structures that include:

• A zero-tolerance policy against forced labor, child labor, and human trafficking.
• Codes of Conduct that mandate compliance with all applicable laws, ethical behavior, and the respect of human rights.
• Internal reporting mechanisms that allow employees to confidentially raise concerns.

Identifying and Assessing Risk

While our operational risk is considered lower than that of businesses in manufacturing-intensive industries, we recognize potential exposure in areas such as:

• Third-party IT service providers
• Cloud and hosting supply chains
• Outsourced technical development teams
• Regions with weaker labor protections

Our risk assessment methods comprise supplier screenings, labor rights evaluations based on location, regular contract reviews, and background checks on business partners and service providers.

Due Diligence Processes

Our due diligence program includes the following measures:

• Supplier onboarding assessments
• Verification of compliance with Modern Slavery Act obligations
• Ongoing evaluation of service providers identified as high-risk
• Contractual requirements mandating downstream supplier compliance

Actions Taken During the Reporting Period

Over the course of this fiscal year, the Companies have:

• Updated supplier agreements to reinforce anti-slavery clauses
• Required key service providers to confirm compliance with the Modern Slavery Act
• Increased internal awareness of labor rights and ethical sourcing
• Enhanced monitoring of subcontractors in categories assessed as high-exposure

Training and Awareness

Employees working in procurement, legal, compliance, security, and operations are provided with training focused on:

• Recognizing indicators of forced labor
• Understanding supplier due diligence requirements
• Applying internal escalation procedures for concerns

Grievance and Whistleblowing Mechanisms

The Companies offer confidential reporting channels for employees, contractors, suppliers, and other third parties to report any potential violations. All reports are promptly investigated, and corrective actions are implemented as needed.

Measuring Effectiveness

We monitor several key indicators to assess the effectiveness of our measures, including:

• The number of risk assessments conducted
• Rates of completion for internal training programs
• The number of reported or confirmed incidents, which are expected to remain at zero

Ongoing Commitment

Maytech Communications Ltd and Kiteworks Europe AG pledge to continually improve our approach by:

• Strengthening supplier oversight mechanisms
• Enhancing transparency in our reporting
• Further aligning our practices with international human rights standards
• Advancing collaborative efforts to identify and mitigate risks

Approval

This joint statement has been reviewed and approved by the Director of Kiteworks Europe AG, the parent company.

Dario Perfettibile, Kiteworks Europe AG
Date: 30 January 2026