Disclosure Statement on Modern Slavery Act for the calendar year 2025

Our Position On Modern Slavery

Blancco Technology Group Limited, including our direct and indirect subsidiaries (“Blancco”),strictly prohibits all forms of slavery, human trafficking, forced labour, and child labour across our operations and supply chain. We are committed to identifying and mitigating any such risks. Under no circumstances will we tolerate forced labour, bonded or indentured labour (including debt bondage), involuntary prison labour, slavery, or trafficking of persons—whether within our own operations or by any of Blancco’s suppliers, their suppliers (collectively referred to as “Suppliers”),or for any other purpose.

As a signatory to the United Nations (UN) Global Compact, Blancco upholds its Ten Principles, which include supporting and respecting internationally recognised human rights and ensuring that we are not complicit in any human rights violations. Our stance on modern slavery is clearly articulated in our Code of Business Conduct which mandates that all suppliers demonstrate legal and ethical compliance—particularly with respect to modern slavery prevention.

About Us

Blancco is a global leader in data erasure and mobile diagnostics, delivering trusted, secure, and certified solutions that empower organizations to manage end-of-life data and IT assets responsibly.

With a strong commitment to innovation, Blancco holds more than 40 patented or patent-pending technologies. Our solutions are relied upon by enterprises, government agencies, and IT asset disposition (ITAD) providers across multiple regions for their proven reliability, robust security, and compliance with international standards.

Core Services

• Certified data erasure for IT assets and storage devices
• Mobile diagnostics and erasure solutions
• Compliance and risk management support
• Sustainability-focused IT asset lifecycle management

Modern Slavery Statement

This Modern Slavery Statement reflects our commitment to being a responsible and principled organization, aligned with our core values. It also addresses the requirements of various international legislations, including the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act, the UK Modern Slavery Act, the Australian Modern Slavery Act, the German Act on Corporate Due Diligence in Supply Chains, the California Transparency in Supply Chains Act, and the Norwegian Transparency Act. The Statement outlines the actions undertaken during the calendar year 2025.

Accordingly, any references to Blancco’s efforts to prevent modern slavery within its supply chains and business operations, including its policies, processes, and procedures — extend to all Blancco entities unless explicitly stated otherwise. For the purposes of this statement, terms such as “Blancco,” “the company,” “we,” “us,” and “our” refer collectively to Blancco, its subsidiaries, and controlled entities, unless the context indicates otherwise.

Our Supply Chain

Blancco’s core business activities are generally assessed as low risk for modern slavery and labour rights violations. The company does not engage in manufacturing, and its primary operations are carried out by a highly skilled and specialised workforce.

Blancco’s operations are underpinned by a global supply chain that supports the delivery of goods and services essential to our business. Our supplier base includes:

• Providers of staff support and office maintenance services (e.g., catering, cleaning, waste
• management)
• IT infrastructure and cloud service providers
• Recruitment and staffing agencies

The majority of our suppliers are based in the European Union and include global providers of IT equipment and infrastructure

This low-risk profile also extends to the services and solutions Blancco procures, which predominantly consist of software and professional services. These characteristics significantly reduce the likelihood of exposure to exploitative labour practices within both our direct operations and our supply chain.

Blancco maintains a zero-tolerance policy toward slavery and human trafficking. We have no reason to believe that such practices exist within our supply chains. However, should any instance of non-compliance be identified and not resolved in a timely manner, Blancco will take decisive action, including the termination of the business relationship.

Our Risk Assessment

We assess modern slavery risks by reference to factors including geographic exposure, sector-specific vulnerabilities, the nature of services and products procured, and the profile of our business relationships. These assessments are reviewed periodically and updated to reflect changes in our operating environment or emerging risk indicators.

As part of our commitment to responsible and lawful business conduct, we have implemented a

Visual Compliance screening process — a robust export control screening mechanism designed to ensure strict adherence to the export control laws and regulations of the United States of America and the European Union. Prior to entering into any engagement, all prospective customers are screened against applicable restricted party lists, sanctions regimes, and export control databases. This process enables us to ensure that we do not knowingly engage with parties that may be involved in activities contrary to law or inconsistent with our ethical standards, including those that could be linked to exploitative labour practices or forced labour networks.

Ongoing Monitoring

Where risk factors are identified through our screening or assessment processes, we undertake enhanced due diligence as appropriate. We remain vigilant to red flags that may indicate the presence of modern slavery risks and are committed to taking appropriate remedial action where concerns arise.

KPI Indicators

We measure the effectiveness of our efforts to combat modern slavery and human trafficking through a set of defined Key Performance Indicators (KPIs), which are reviewed annually. The table below sets out our performance against these KPIs for the calendar year 2025.

KPI	Target	2025 Performance
Percentage of staff completing annual modern slavery and compliance training	95%	98%
Percentage of customers screened through our Visual Compliance process prior to engagement	100%	100%
Investigate and resolve all customer screening alerts flagged through Visual Compliance	100%	100%
Monitor and review the outcomes of all whistleblowing cases reported	100%	No Whistleblowing cases received

Policies

We acknowledge that strong, well-governed internal policies are essential to preventing modern slavery and human trafficking across our operations and the wider networks in which we engage. Over the past year, we undertook a deliberate, structured initiative to consolidate and formalise our policy framework. As part of this effort, we organised our policies under four key pillars, enhancing clarity, strengthening accountability, and ensuring comprehensive coverage across all areas of our business.

Compliance & Risk	Data Privacy, Information Security & Confidentiality	Procurement & CSR	Travel & Expenses
Blancco Group Code of Business Conduct	Blancco Group Retention Policy	Blancco Group Procurement Policy	Blancco Group Travel and Expenses Policy (APAC)
Blancco Group Anti- Corruption & Bribery Policy	Blancco Group IT Service Policy	Blancco Group CSR Statement	Blancco Group Travel and Expenses Policy (EMEA)
Blancco Group Risk Management Policy	Blancco Group Confidential Information Policy	Blancco Group Health Safety and Environmental Policy	Blancco Group Travel and Expenses Policy (General)
Blancco Group Whistleblowing Policy Blancco Group Export Control Policy	Blancco Group Information Security Policy	Blancco Group Quality Policy

1. Compliance & Risk: Our Compliance & Risk policies establish the ethical and regulatory foundation upon which our business operates. These policies set out our zero-tolerance stance towards bribery, corruption, and unlawful conduct, and provide the framework within which risks — including those relating to modern slavery, are identified, escalated, and managed. All personnel are expected to adhere to these standards in their day-to-day conduct and business relationships.

2. Data Privacy, Information Security & Confidentiality: We recognise that the protection of personal data and confidential information is intrinsically linked to the dignity and rights of individuals. Our policies in this area ensure that personal information, including that of workers across our operations, are handled lawfully, securely, and with appropriate safeguards. This also supports our ability to maintain the integrity of our due diligence and screening processes.

3. Procurement & CSR: Our Procurement, Quality, Health, Safety & Environment (HSE), and Corporate Social Responsibility (CSR) policies reflect our commitment to responsible sourcing and sustainable business practices. These policies embed ethical considerations into our procurement decisions and operational standards, ensuring that quality and safety are never achieved at the expense of people’s rights and wellbeing.

4. Travel & Expense: Our Travel & Expense policy governs how business travel and expenditure are conducted and reported. This policy promotes transparency and accountability in employee conduct, discouraging practices that could facilitate improper payments or obscure relationships that may carry modern slavery risk.

Together, these policies form an integrated governance framework that underpins our approach to ethical business conduct and our commitment to combating modern slavery in all its forms. All policies are made available to our employees and are subject to periodic review to ensure they remain current, effective, and aligned with evolving legal and ethical standards.

UN Global Compact

Since 2022, Blancco has been a member of the United Nations Global Compact and remain committed to fulfilling the responsibilities of this membership. In line with the UNGC’s ten principles on human rights, labour, the environment, and anti-corruption, we integrate these expectations into our operations and strategic decision-making.

We also support the United Nations Sustainable Development Goals, including the commitment to eliminate all forms of modern slavery, forced labour, and human trafficking. These goals reflect our organisational values and reinforce our belief that ethical and sustainable business practices are both a responsibility and a necessity.

We continue to embed the UNGC principles across our daily operations, governance frameworks, and stakeholder relationships, maintaining a zero-tolerance approach to slavery and human trafficking throughout our business and supply chain.

As part of our obligations as a UNGC signatory, we submit an annual Communication on Progress, publicly reporting the actions we have taken to implement the ten principles and advance the SDGs. This reporting underscores our commitment to transparency and continuous improvement.

Training

To support our company’s values and commitments, all Blancco personnel globally must complete annual training on respect in the workplace, anti-harassment, violence prevention, anti-bribery and anti-corruption, data protection and information security.

We are also committed to building awareness of modern slavery and human trafficking. As part of our ongoing efforts, we are integrating modern slavery training into our broader learning framework, ensuring that employees particularly those in supply chain, procurement, compliance, and customer-facing roles can recognise risks and know how to escalate concerns appropriately.

We believe that an informed and values-driven workforce is one of our most effective tools in the fight against modern slavery, and we remain committed to strengthening our training offering in this area on an ongoing basis.

Our Effectiveness In Combatting Human Trafficking and Modern Slavery

Our assessment of our own operations and workforce indicates that they are at low risk of modern slavery. Our work is technical and professional in nature, placing us in a comparatively low-risk sector, with a workforce composed of skilled professionals employed full-time. We do not engage seasonal or migrant workers within our operations.

We are committed to fostering responsible labour practices through voluntary labour engagement, thoughtful innovation, and the promotion of our core company values of equity, respect, and integrity. At the time of hiring, we verify all personnel to help identify whether any individual may be subject to forced or involuntary labour, including forced, indentured, bonded, or involuntary prison labour. Our training programmes cover anti-violence, workplace respect, and management responsibility to raise awareness and promote the reporting of, any form of human trafficking, including the transporting, harboring, or recruiting of individuals under threat, coercion, fraud, or force with the intent of exploitation.

Working with suppliers and partners who share and reflect our values is of utmost importance to us. To reduce the possibility of forced labour, slavery, or human trafficking within our supply chains, we require new suppliers and partners to be bound by contractual obligations to comply with all applicable laws and to uphold standards consistent with our own ethical commitments.

To track our effectiveness, maintain high standards of conduct, and drive continuous improvement across our operations and supply chain, we:

• require our suppliers to contractually agree to compliance with all applicable laws and ethical standards;
• regularly review our policies supporting human rights — including our anti-harassment, anti-violence, anti-discrimination, and diversity and belonging policies — to ensure alignment with global regulations and evolving best practices;
• protect whistleblowers in accordance with our whistleblowing policy and procedure, ensuring that individuals can raise concerns safely and without fear of retaliation;
• monitor, investigate, and wherever possible, remediate any complaints received and substantiated that negatively affect human rights within our operations or supply chain;
• track the completion rates and effectiveness of employee training programmes to ensure awareness is maintained across the organisation;
• implement our Visual Compliance screening process to ensure strict adherence to the applicable export control laws of the United States of America and the European Union, screening customers prior to engagement to safeguard against relationships that may carry associated human rights risks; and
• evaluate our processes on an ongoing basis to determine whether it would be appropriate to adopt further policies, procedures, or third-party frameworks in support of our commitments.

Blancco is firmly committed to respecting human rights in all aspects of our business and shall continue to review and strengthen our policies and practices to prevent, to the fullest extent practicable, child labour, modern slavery, human trafficking, and exploitation across our company and supply chain.

This statement has been approved on behalf of Blancco Group by

Satoru Ogawa
Chief Financial Officer
Blancco Group

April 07, 2026.