Modern Slavery Act 2015 – Section 54 Compliance

Smart Audio Technologies Limited

Company Registration Number: 11088278

1. Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and outlines the steps taken by Smart Audio Technologies Limited (“Smart Audio” or “the Company”) to prevent modern slavery and human trafficking within our organisation and supply chains.

Smart Audio operates a zero-tolerance approach to slavery, servitude, forced or compulsory labour and human trafficking.

As a supplier of mission-critical communication technologies into defence and security environments, we recognise that ethical supply chain integrity is not only a legal obligation but also fundamental to operational resilience, national security and public trust.

2. Our Business and Defence Context

Smart Audio is a United Kingdom-based deep-technology company developing advanced communication systems for defence, aerospace, emergency services and other security-critical sectors.

Given the nature of our defence and security activities, supply chain integrity, traceability and governance are central to our operations.

Our supplier base primarily comprises UK-based and NATO-aligned partners operating within regulated manufacturing environments.

We prioritise:

UK-based manufacturing capabilityAllied and low-risk jurisdictions

ISO-aligned production environments

Structured and auditable procurement processes

3. Our CommitmentSmart Audio is committed to:

Ensuring modern slavery does not occur within our operations

Mitigating slavery and human trafficking risks within our supply chain

Acting ethically and with integrity in all commercial relationships

Supporting ethical standards aligned with UK Ministry of Defence and Crown Commercial Service procurement expectations

We will not knowingly engage with any organisation involved in modern slavery practices.

4. Governance and Accountability

Responsibility for anti-slavery compliance rests with the Company Directors.

The Board:

Reviews this statement annually

Oversees proportionate, risk-based due diligence procedures

Ensures supplier governance controls remain effectiveMaintains oversight of ethical risk exposure across the supply chain

Modern slavery risk is managed as part of our broader operational, reputational and supply chain risk framework.

5. Risk Assessment and Due Diligence

Smart Audio adopts a structured, risk-based approach to supplier oversight.

Our due diligence measures include:

Consideration of supplier jurisdiction and risk profile

Preference for UK and allied manufacturing partners

Contractual confirmation of compliance with applicable labour lawsInclusion of modern slavery provisions within supplier agreements

Ongoing monitoring proportionate to supplier risk exposure

Where elevated risk is identified, enhanced review procedures may be implemented.

6. Internal Policies and Reporting

Smart Audio maintains policies supporting this commitment, including:

Code of Business Conduct

Ethical Procurement Principles

Whistleblowing and Confidential Reporting Policy

Equal Opportunities and Fair Employment Policy

Supplier Code of Conduct

Employees and contractors are encouraged to raise concerns confidentially and without fear of retaliation.

7. Training and Awareness

Personnel involved in procurement and supplier management are made aware of:

Indicators of modern slavery

Escalation and reporting procedures

Public sector procurement expectations

Training and awareness measures are reviewed periodically.

8. Continuous Improvement

Smart Audio recognises that modern slavery risks evolve across global supply chains.

We commit to:

Reviewing risk exposure annually

Strengthening due diligence controls where appropriate

Maintaining transparency consistent with UK Ministry of Defence and Crown Commercial Service procurement frameworksLast updated:

Last Updated: 13 January 2026