Anti-Trafficking Statement

Statement Summary

Modern slavery encompasses slavery, forced and compulsory labour, and human trafficking, whereby individuals are deprived of their freedom and are exploited for commercial or personal gain as defined in the Modern Slavery Act 2015. All forms of modern slavery have in common the deprivation of a person’s liberty by another to exploit them for commercial or personal gain, and amount to a violation of an individual’s fundamental human rights.

AdCellerant is committed to combating and preventing slavery and human trafficking, and to acting with integrity in all our dealings, relationships, and supply chains.

AdCellerant expects the same high standards from all our staff, suppliers, contractors, and those with whom we do business. The aim of this statement is to highlight and confirm the key procedures and measures that AdCellerant has put in place to ensure that the use and support of slavery and human trafficking within the AdCellerant supply chain and the AdCellerant organization is strictly prohibited.

Although we are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015, we are making this voluntary statement to show our commitment to ethical trading principles and as above, to set out the steps we are taking to identify risks and tackle modern slavery and human trafficking in our business and in our supply chains.

The Modern Slavery Act 2015 covers four key criminal activities:

1. Slavery

where ownership is exercised over an individual.

2. Servitude

involves the obligation to provide service imposed by coercion.

3. Forced and compulsory labour:

all work or service not voluntarily performed, which is obtained from an individual under the threat of force or penalty.

4. Human trafficking:

involves arranging or facilitating the travel of another to exploit them

Other forms of modern slavery, which will not be tolerated by AdCellerant but are not specifically referenced in the Modern Slavery Act of 2015, include, but are not limited to, Child Labor: While not always illegal in the jurisdiction in which it takes place, child labor involves the employment of children that is exploitative or is likely to be hazardous to or interfere with a child’s education, health (including mental health), physical well-being, or social development.

About AdCellerant

AdCellerant is a global, digital-minded, tech-driven digital marketing company in the AdCellerant Group is: AdCellerant UK Limited, based in London, United Kingdom; and the ultimate parent company, AdCellerant LLC, with its head office in Denver, United States.

Within the context of this statement, “Supplier” shall refer to any vendor, software, supplier, or external organization with which AdCellerant has a business relationship.

AdCellerant has a number of policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business, each of which is continually reviewed and updated.

Our Anti-trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due Diligence: Prevention and Monitoring Measures

AdCellerant has mechanisms to combat and prevent slavery and human trafficking in line with this statement. The primary goal of these mechanisms is to prevent onboarding any supplier who is unable to meet the requirements of the Anti-trafficking Policy and, secondarily, to monitor active suppliers to validate that they maintain compliance during the relationship with AdCellerant. These mechanisms include:

Onboarding – Prior to working with a new supplier, AdCellerant validates that they comply with the Modern Slavery Act of 2015. Failure to comply will result in the supplier being removed from consideration. The vendor may be provided an opportunity to address any shortcomings (e.g., develop and publish a policy) within an agreed-upon timeline that resolves the deficiency to AdCellerant’s satisfaction.

Annual Review – AdCellerant’s Vendor Management Program annually validates that suppliers are meeting their contractual, compliance, and service obligations. The vendor may be provided an opportunity to address any shortcomings (e.g., develop and publish a policy) within an agreed-upon timeline that resolves the deficiency to AdCellerant’s satisfaction.

The AdCellerant Risk Registry includes risks associated with suppliers not being compliant with the Modern Slavery Act at any point during their relationship with AdCellerant. The Risk Management policy includes a Treatment Plan for any risks that exceed the acceptable threshold. The Risk Registry is part of the quarterly Security & Compliance Steering Committee meeting agenda so risks are reviewed continually throughout the year.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, employees are trained upon hire and annually thereafter on AdCellerant policies, which include the Anti-Trafficking Policy (Modern Slavery Act 2015). We also encourage our business partners to provide training to their staff and suppliers, and providers.

As with any policy that is not being properly followed, or if you have questions about this policy, you may contact us at
(800) 949-3326, dataprivacy@adcellerant.com
or:
Attn: Legal Counsel/Privacy
865 Albion St Suite 400
Denver, CO 80220

We have zero tolerance for slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our ethics, we have in place a rigorous supply chain compliance program (as specified above), and to further ensure compliance, AdCellerant includes language that supports the objectives of this statement within our supplier contracts, including the incorporation of:

1. Specific prohibitions against slavery or servitude, the use of forced, compulsory, or trafficked labour, and the use of child labor in line with this statement and our Anti-trafficking Policy.

2. Provision for our contracted suppliers to hold their own suppliers to the same standards. We also reserve the right to terminate any contractual arrangement if there is a breach of this statement and our Anti-trafficking Policy.

AdCellerant reports on the status of compliance with the Modern Slavery Act 2015 on an annual basis (beginning Q2 2026, 12 months after implementation). The reporting will be done by GRC and shall include:

Violations of this policy by Suppliers, Employees, and anyone else covered by the Anti-trafficking Policy.

1. Status of Contractual Agreements with provisions related to the Anti-trafficking Policy.

2. Risk Registry score and any associated remediation actions

3. Any third-party review of this policy and the effectiveness of associated controls, if performed within the reporting period.

4. Suppliers denied onboarding for non-compliance, assisted to become/remain compliant, and those removed for non-compliance

1. Target 100% Training of Employees

2. Pre-onboarding and annually thereafter, the AdCellerant Vendor Program requires vendors to meet this and other regulatory standards as applicable to AdCellerant.

3. AdCellerant is audited by external third parties annually

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the AdCellerant Group’s slavery and human trafficking statement for the financial year ending 2025/2026. It was approved by the board in June 2025

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