Modern Slavery Act 2015 - Transparency Statement

CodeLens Ltd is a global technology company specializing in AI-powered software products, consulting services, system integration, and technology solutions. Our business is organized to deliver innovation and value to clients across multiple sectors and geographies.

CodeLens operates with a workforce comprising permanent employees, contractors, and consultants. We maintain offices and service delivery centers in multiple jurisdictions and work with clients, partners, and suppliers worldwide.

CodeLens's supply chain primarily consists of:

• • Technology and software vendors
• • Cloud and infrastructure service providers
• • Professional services providers and consultants
• • Recruitment and staffing partners
• • Facilities and support service providers
• • Hardware and IT equipment suppliers

As a technology and services company, we do not operate manufacturing facilities or maintain a tangible goods supply chain.

CodeLens maintains a zero-tolerance policy towards slavery, forced labor, child labor, servitude, and human trafficking. Our commitment includes:

• • Employment Practices: Fair wages, safe working conditions, voluntary employment, and freedom of movement for all employees and workers
• • Supplier Code of Conduct: Requirements that all suppliers comply with applicable labor laws and human rights standards
• • Whistleblowing: Multiple confidential channels for employees and stakeholders to report concerns without fear of retaliation
• • Transparency: Annual review and public reporting on our modern slavery prevention efforts

CodeLens has implemented the following due diligence measures to identify and assess slavery and trafficking risks:

• • Supplier assessment and qualification procedures that include evaluation of labor practices and compliance with human rights standards
• • Contractual requirements for suppliers to comply with applicable labor laws and CodeLens's Supplier Code of Conduct
• • Risk-based audit programs focused on high-risk suppliers and geographies
• • Regular review of employment practices and compensation structures within our organization
• • Investigation protocols for any reported concerns or incidents

CodeLens has assessed its risk profile as follows:

Identified indirect risks require ongoing monitoring:

• • Outsourced services and offshore development work
• • Third-party facilities and support services
• • Recruitment and staffing agencies
• • Professional services and consulting partnerships

CodeLens monitors the following KPIs to measure the effectiveness of our modern slavery prevention efforts:

• • Number of employees and contractors trained on modern slavery awareness and reporting procedures
• • Percentage of key suppliers completing due diligence assessments and confirming compliance with our Supplier Code of Conduct
• • Number of reported concerns or incidents related to modern slavery or human trafficking
• • Number of audits conducted and findings identified
• • Corrective actions implemented and their completion status

CodeLens provides regular training to all employees, with particular emphasis on roles involved in procurement, HR, and supplier management:

• • Mandatory induction training for all new employees covering our commitment to preventing slavery and trafficking
• • Annual refresher training on modern slavery awareness and reporting obligations
• • Role-specific training for procurement and HR teams on due diligence and risk assessment
• • Supplier awareness sessions to ensure partners understand our expectations and compliance requirements

CodeLens regularly reviews the effectiveness of its modern slavery prevention activities through:

• • Annual effectiveness audits and assessments of our policies and procedures
• • Analysis of audit findings, supplier assessments, and reported concerns
• • Feedback from employees, suppliers, and stakeholders
• • Quarterly management reviews of KPIs and corrective action status

Any suspected or confirmed incidents of slavery or human trafficking are investigated immediately and reported to appropriate authorities. Remediation measures include:

• • Immediate investigation and documentation of all reported concerns
• • Collaboration with law enforcement and relevant authorities
• • Support and assistance to affected individuals
• • Implementation of corrective and preventative measures
• • Termination of business relationships where violations are confirmed and not remediated

CodeLens is committed to transparency and accountability:

• • This statement is reviewed and updated annually in compliance with Section 54 of the Modern Slavery Act 2015
• • Senior leadership is accountable for the implementation and oversight of our modern slavery prevention policies
• • Employees and external stakeholders can report concerns through multiple confidential channels without fear of retaliation
• • We engage with industry peers, customer organizations, and external organizations to strengthen our approach to modern slavery prevention

Any concerns, suspicions, or reports of modern slavery or human trafficking should be escalated immediately through:

• • Direct communication to your manager or HR department
• • CodeLens's Legal and Compliance Department
• • Anonymous whistleblowing channels (where available)
• • Local law enforcement or relevant authorities

CodeLens strictly prohibits retaliation against individuals who report concerns in good faith.

This Modern Slavery and Human Trafficking Policy has been approved by the Executive Leadership of CodeLens Ltd and is reviewed annually to ensure continued alignment with international standards, legal requirements, and best practices.