Modern Slavery & Human Trafficking Statement 2025

CUSTOMERTIMES GROUP – CUSTOMERTIMES CORP. and its affiliates (“CUSTOMERTIMES”, “CT”, “we”, “our”) is committed to conducting business ethically, responsibly, and in full compliance with applicable human rights and labor standards. We have zero tolerance for any form of modern slavery, forced labor, servitude, child labor, or human trafficking in our operations or supply chains.

This Statement outlines the steps taken by Customertimes during the financial year ending January 31, 2026 to prevent modern slavery and human trafficking in our global business and supply chains, in accordance with:

• UK Modern Slavery Act 2015
• Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (2024)
• California Transparency in Supply Chains Act
• U.S. Trafficking Victims Protection Act (TVPA) & U.S. FAR 52.222-50
• EU Corporate Sustainability Due Diligence Directive (CSDDD)
• OECD Due Diligence Guidance for Responsible Business Conduct
• UN Guiding Principles on Business and Human Rights (UNGPs) & ILO Core Conventions
• Ethical Trading Initiative (ETI) Base Code

2. Our Company and Operations

Customertimes is a U.S.-based global technology consulting and software development company specializing in digital transformation, cloud solutions, and enterprise platforms such as Salesforce and SAP. Through our international operating entities, we serve clients across North America, Europe, Africa and Asia.

We engage with approximately 1,300 people worldwide, including employees, contractors, and consultants, and we work with an extended network of suppliers and delivery partners.

3. Our Supply Chains

Our supply chains primarily consist of:

• Professional and technical IT services
• Software tools, cloud infrastructure, and development platforms
• Recruitment and staffing partners
• Corporate services (legal, accounting, HR, travel, facilities)

While our operations are predominantly knowledge-based and considered low risk for modern slavery, we are aware that indirect risks can exist within:

• Recruitment and staffing channels
• Subcontracted service delivery
• Technology hardware or equipment providers
• Suppliers operating in higher-risk jurisdictions

We continually work to identify, assess, and mitigate such risks.

4. Policies Supporting Our Commitment

Customertimes has established clear policies to ensure ethical and responsible business practices, including:

• Modern Slavery and Human Trafficking Policy
• Supplier Code of Conduct
• Anti-Bribery and Corruption Policy
• Whistleblowing Policy
• Recruitment and Employment Policy
• Data Protection & Privacy Policy

Our Supplier Code of Conduct requires all suppliers to uphold internationally recognized labor and human rights standards, including the prohibition of forced, bonded, or child labor.

5. Due Diligence and Supplier Oversight

We continue to strengthen our due diligence practices to prevent modern slavery across our supply chain. Key measures include:

• Pre-engagement supplier risk assessments
• Contractual commitments requiring compliance with our Modern Slavery Policy and Supplier Code of Conduct
• Inclusion of audit, monitoring, and termination rights for violations
• Enhanced monitoring of suppliers in higher-risk sectors or jurisdictions
• Escalation procedures for suspected breaches

Where risks are identified, we work collaboratively with suppliers to ensure corrective actions or, when required, discontinue the relationship.

6. Risk Assessment

We assess modern slavery risk based on:

• Geography (countries with higher prevalence of forced labor or weak enforcement)
• Sector risk (outsourced labor, subcontracting, or manufacturing)
• Nature of services (recruitment, temporary labor, physical labor)
• Supplier performance and transparency

Although the overall risk within our direct operations remains low, we continuously evaluate our supply chain to ensure early detection of vulnerabilities.

7. Training and Awareness

Employees involved in procurement, vendor management, HR, and recruitment receive targeted training on:

• Identifying signs of modern slavery
• Reporting procedures and escalation paths
• Supplier engagement and compliance expectations

Training is refreshed annually and updated as legal requirements evolve.

8. Reporting and Whistleblowing

We encourage employees, suppliers, and business partners to report any concerns about unethical conduct or potential modern slavery through our confidential reporting channel:

Email: whistleblower@customertimes.com

Reports may be made anonymously, and we strictly prohibit retaliation against anyone reporting in good faith.

9. Monitoring, Effectiveness, and Continuous Improvement

We monitor the effectiveness of our actions through:

• Supplier assessments and compliance reviews
• Tracking training completion rates
• Reviewing reported incidents and corrective actions
• Monitoring changes in global regulatory frameworks

Customertimes is committed to improving our processes and strengthening our due diligence framework as part of our long-term approach to responsible business conduct.