Calen Modern Slavery Statement

Calen's supply chain is concentrated in a small number of categories, reflecting our nature as a software business. It primarily comprises top-tier global banking infrastructure partners who provision our Virtual Accounts and clearing rails, secure cloud data hosting providers, licensed software service providers whose tools we integrate into our platform, and professional consulting and advisory firms who support our legal, compliance, and financial operations.

Before any primary contractor, cloud infrastructure provider, or third party API provider is onboarded to our network, they pass through a structured vetting process. This process reviews the counterparty's corporate governance standards, its own published human rights and labour policies where applicable, its jurisdiction of incorporation, and any publicly available record of labour, safety, or ethical violations. We decline to engage a prospective partner where this review raises a concern we cannot satisfactorily resolve, and we build a right to audit and a right to terminate on ethical grounds into our standard supplier contracts.

This statement operates alongside, and is reinforced by, the rest of Calen's internal compliance architecture. Our Whistleblowing Policy gives every employee, remote software developer, independent contractor, and external supplier a safe, confidential route to report a genuine concern about exploitation or human rights abuses without fear of retaliation. Our core code of business conduct sets the ethical standard we expect of everyone who works for or with Calen, and our anti-financial crime frameworks, including our anti-money laundering and know your business procedures, are designed to prevent our platform from being used to facilitate the proceeds of exploitation of any kind.

Together, these policies are engineered to work as a single system. A concern raised under any one of them is treated with the same seriousness and routed to the same independent compliance function described in our Whistleblowing Policy, ensuring that a report of suspected exploitation is never lost between departments or overlooked because it falls outside a single policy's narrow scope.

Calen operates a distributed corporate footprint, with core management functions and engineering teams located across our operating jurisdictions and a number of international engineering houses we partner with for specialist development work. We continually review this footprint as part of our risk assessment process, paying particular attention to jurisdictions or engagement models that carry a higher inherent risk of labour exploitation, such as high-volume outsourced data entry or unmanaged subcontracting chains.

We maintain continuous monitoring protocols to verify that our global service partners, data entry contractors, and technical support vendors comply with the international labour standards, legal minimum wage requirements, and safe working environment obligations applicable in their own jurisdiction. Where a partner engages subcontractors of its own to deliver services to Calen, we require that partner to extend equivalent standards down its own chain, and we reserve the right to request evidence of compliance at any time.

We measure the effectiveness of this statement against clear, trackable benchmarks rather than treating it as a static annual document. We monitor our organisational progress through the following indicators.

• Zero reported incidents of modern slavery, forced labour, or human trafficking connected to our own operations or our direct supply chain.
• One hundred percent completion of our regulatory compliance training modules by all employees, contractors, and engineering partners required to complete them.
• Full verification of background check and right to work validations for every individual onboarded into a role with access to Calen systems or Customer data, with no outstanding or incomplete checks.

Where any of these benchmarks is not met in a given reporting period, our compliance function investigates the shortfall, reports it to executive leadership, and puts a corrective action plan in place before the next reporting cycle.

Every member of our internal team, every distributed software engineer engaged through a partner engineering house, and all compliance staff are required to complete a mandatory awareness module on modern slavery and human trafficking at least once a year. This training covers how to recognise potential exploitation indicators within international trade and outsourcing networks, what to do if a concern arises, and how our Whistleblowing Policy protects anyone who raises one in good faith.

Completion of this training is tracked centrally by our compliance function and forms part of the key performance indicators described in section 5. By embedding this awareness across every team, including those furthest from our direct operations, we ensure that our commitment to preventing modern slavery is integrated into how Calen actually works, not treated as a document that sits apart from it.

This statement is reviewed and approved annually by Calen's senior leadership and is published on our website in accordance with our transparency commitments.