Modern Slavery Act Statement

38 Labs LLC is committed to conducting its business ethically, responsibly, and with respect for human rights. We have zero tolerance for modern slavery, forced labour, human trafficking, child labour, or any form of exploitation within our business operations or supply chain.

Although 38 Labs is not currently required to publish a statement under Section 54 of the UK Modern Slavery Act 2015, we voluntarily maintain this statement to demonstrate our commitment to responsible business practices and transparency.

Our Business

38 Labs is an AI and technology consulting company providing artificial intelligence, software development, data, and technology consulting services to clients internationally.

Our operations are primarily service-based and rely on a relatively limited supply chain, consisting principally of professional service providers, technology and software vendors, contractors, and other business suppliers.

We expect all employees, contractors, suppliers, and business partners acting on behalf of 38 Labs to conduct themselves in accordance with applicable laws and our standards of ethical business conduct.

Our Commitment

38 Labs does not tolerate:

• Forced, bonded, or involuntary labour
• Human trafficking or exploitation
• Child labour
• Slavery or servitude
• Recruitment practices involving coercion, threats, or deception
• The withholding of identity documents or wages as a means of controlling workers
• Any other practices that violate fundamental labour or human rights

We expect our suppliers and business partners to uphold equivalent standards and to comply with applicable employment, labour, human rights, and anti-trafficking laws.

Policies and Standards

Our commitment to preventing modern slavery is supported by our broader corporate governance and ethical business practices, including our Code of Conduct and Code of Ethics.

These standards establish expectations regarding:

• Respectful and lawful treatment of workers
• Compliance with applicable employment and labour laws
• Ethical business conduct
• Respect for human rights
• Confidentiality and responsible handling of information
• Appropriate conduct by employees, contractors, and third parties

Risk Assessment and Due Diligence

Given the nature and scale of our business, 38 Labs considers the risk of modern slavery within its direct operations to be limited. Nevertheless, we recognise that risks may exist within extended supply chains, particularly where third-party labour, outsourced services, or suppliers operating in higher-risk jurisdictions are involved.

We seek to manage these risks through proportionate due diligence when engaging suppliers, contractors, and other third parties.

Depending on the nature and risk profile of the relationship, this may include:

• Reviewing the nature and location of the supplier’s operations
• Assessing the supplier’s compliance with applicable laws and ethical standards
• Requiring suppliers and contractors to comply with our contractual and ethical requirements
• Considering modern slavery and labour-rights risks when appropriate during supplier selection and review
• Addressing identified concerns through appropriate corrective action

We expect suppliers to notify us promptly if they identify any actual or suspected instance of modern slavery or forced labour connected with services provided to 38 Labs.

Employees and Contractors

We seek to ensure that individuals working for or on behalf of 38 Labs are engaged voluntarily and under lawful working arrangements.

We do not use forced or involuntary labour, and we do not knowingly engage individuals or organisations involved in human trafficking, forced labour, or other forms of modern slavery.

Employment and contractor relationships are managed in accordance with applicable laws and contractual requirements.

Training and Awareness

38 Labs promotes awareness of ethical business practices and the risks associated with modern slavery.

Relevant personnel are expected to understand their responsibilities and to raise concerns where they become aware of conduct that may breach our policies, applicable law, or our commitment to human rights.

Where appropriate, additional guidance or training may be provided based on the individual’s role and the level of risk associated with the relevant business activity.

Reporting Concerns

Employees, contractors, suppliers, and other stakeholders are encouraged to raise concerns regarding suspected modern slavery, forced labour, human trafficking, or other serious ethical concerns.

Concerns may be raised with company management or through the appropriate reporting channels made available by 38 Labs.

All concerns will be considered seriously and, where appropriate, investigated and addressed in accordance with our internal procedures and applicable law.

Monitoring and Continuous Improvement

38 Labs recognises that preventing modern slavery requires ongoing attention. We periodically review our policies, supplier relationships, and business practices to identify opportunities to strengthen our approach.

Where risks or concerns are identified, we will take proportionate steps to investigate, mitigate, and address them.

We will continue to develop our approach as our business, supply chain, and regulatory obligations evolve.

Governance and Approval

This statement has been approved by the management of 38 Labs LLC and is reviewed periodically to ensure that it remains appropriate to our business and operations.