Modern Slavery

Cloud Drift Ltd

1. Introduction

Cloud Drift Ltd (hereinafter "the Company") is a UK-based software consultancy specialising in custom software delivery, DevOps, and artificial intelligence. This statement sets out the Company's commitment to preventing modern slavery and human trafficking across our operations and supply chains in accordance with the Modern Slavery Act 2015. The Company maintains a zero-tolerance position on modern slavery and human trafficking in any form, including slavery, servitude, forced or compulsory labour, and human trafficking, and expects the same standards from all contractors, suppliers, and business partners.

This statement is made by Cloud Drift Ltd and its wholly owned Polish subsidiary, Cloud Drift Sp. z o.o.

2. Organisational Structure

Cloud Drift Ltd is a boutique software consultancy incorporated in the United Kingdom with its principal place of business in London.

The Company's organisational structure is as follows:

• Cloud Drift Ltd (UK parent company)
• Cloud Drift Sp. z o.o. (Poland, 100% subsidiary)

The Company does not own or control any additional subsidiaries or joint ventures beyond this structure.

3. Our Business

Cloud Drift provides technology consulting services across:

• Custom software development and delivery
• DevOps services
• AI and Large Language Model integration for regulated industries

Our clients are principally in regulated sectors including fintech, banking, retail, healthcare, and professional services. Our technical stack is Microsoft-centric (Azure, .NET, Databricks) with extensive use of artificial intelligence tools and modern development practices.

4. Supply Chain

The Company's supply chain is limited in scope and comprises the following categories:

• Independent contractors and specialist freelancers
• Professional services providers (accountancy, tax, legal advisory)
• Cloud infrastructure and software licensing providers (Microsoft Azure, Microsoft 365, OpenAI/ChatGPT, Anthropic Claude)
• General office and facilities services

The Company does not currently engage staffing agencies. All contractor and employee engagement is managed directly or through established professional service providers with robust compliance frameworks. All suppliers are selected from established, reputable providers operating in the UK and Poland with appropriate compliance certifications.

5. Modern Slavery Risk Assessment

The Company acknowledges that modern slavery and human trafficking can occur in various forms across supply chains. Our risk assessment identifies the following areas as warranting particular attention:

5.1 Contractor and Freelancer Engagement

The majority of our external resource comes from independent contractors and specialist freelancers engaged on project-specific terms. Risk factors include:

• Insufficient identity verification and right-to-work documentation
• Lack of transparency regarding working conditions and contractual terms
• Limited oversight of labour practices in sub-contracted arrangements

5.2 Professional Services Providers

Engagement of accountancy, tax, and legal advisory firms generally presents lower risk given their operating context and regulatory oversight. However, supplier selection is subject to due diligence.

5.3 Cloud and Software Vendors

The Company relies on cloud infrastructure (Microsoft Azure), software licensing (Microsoft 365), and artificial intelligence tools (OpenAI, Anthropic Claude). These large, publicly listed or well-established providers operate under robust compliance and transparency frameworks that substantially mitigate modern slavery risk.

5.4 Geography

Operations in the UK and Poland, both countries with strong labour law frameworks and EU compliance standards, further reduces inherent modern slavery risk compared to operations in higher-risk jurisdictions.

6. Policies and Due Diligence

The Company is committed to operating with integrity and high ethical standards. Our existing policies support this commitment:

6.1 Employment and Contractor Engagement

All employees and contractors are:

• Subject to identity and background verification (as permitted by local law) prior to engagement
• Required to demonstrate right-to-work status in their respective jurisdiction
• Engaged on written terms clearly setting out rates of pay, working hours, and conditions of engagement
• Entitled to fair wages at least meeting applicable national minimum wage requirements

6.2 Supplier Selection and Management

Professional services providers and technology vendors are selected based on:

• Established reputation and market presence
• Evidence of appropriate compliance certifications and governance frameworks
• Documented commitment to ethical business practice
• Financial stability and ongoing viability

6.3 ISO Certifications

The Company holds ISO 9001 (Quality Management) and ISO 27001 (Information Security Management) certifications, demonstrating our commitment to documented, auditable processes and continuous improvement across critical business functions.

6.4 Grievance and Whistleblowing

The Company maintains confidential mechanisms for employees and contractors to raise concerns regarding labour practices, working conditions, or any suspected breach of this statement. Individuals are protected from retaliation for raising concerns in good faith. Details of these mechanisms are communicated to all team members upon engagement.

7. Future Enhancements

While the Company's current operational footprint and supply chain configuration present relatively low inherent modern slavery risk, we are committed to continuous improvement. Planned enhancements for 2026 include:

• Formalisation of modern slavery policy
• Training for leadership and relevant staff on identifying and reporting suspected modern slavery
• Annual review of this statement and assessment of emerging risks as the Company scales

8. Governance and Responsibility

This statement has been approved by the board of Cloud Drift Ltd. Oversight of modern slavery risk and compliance with the Modern Slavery Act 2015 is the responsibility of the Company's senior leadership. The statement will be reviewed annually and updated to reflect any material changes to the Company's operations or supply chain configuration.

Approved by the Board of Cloud Drift Ltd