Modern Slavery and Human Trafficking Statement

Purpose and commitment

Modern slavery and human trafficking are serious crimes and a violation of fundamental human rights. Vault Cloud UK Ltd has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chain.

Our business and supply chains

Vault Cloud UK Ltd provides sovereign cloud services and specialist IT and security consultancy. We operate primarily in the United Kingdom and work with partners and suppliers in the UK, Australia and the United States.

Our supply chain typically includes:

• Cloud and data centre services, connectivity and managed service partners
• Technology vendors, covering hardware, software, licensing and support
• Professional services suppliers, including consultancy, recruitment and subcontractors
• Corporate services such as legal, finance, travel, facilities and utilities

Governance and responsibility

Overall responsibility for this statement and for our approach to modern slavery sits with the Board. Day-to-day ownership is delegated to senior management, who ensure that appropriate policies, supplier controls and reporting arrangements are in place and reviewed periodically.

Policies and controls

• A Code of Conduct setting the ethical standards expected of employees and suppliers
• Whistleblowing and reporting arrangements that allow concerns to be raised confidentially
• Supplier onboarding and due diligence checks proportionate to risk
• Contractual terms requiring compliance with modern slavery legislation

Risk assessment and due diligence

We apply a proportionate, risk-based approach to assessing suppliers, considering the nature of the goods and services provided, labour intensity, geographic risk indicators, and any adverse media or enforcement action.

Training and awareness

We provide awareness guidance to staff involved in procurement and supplier management, to help them identify potential indicators of modern slavery and to ensure concerns are escalated appropriately.

Effectiveness and continuous improvement

We continue to strengthen supplier engagement and improve visibility across our supply chain, with periodic management review of risk controls and the effectiveness of our due diligence.

Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Vault Cloud UK Ltd's modern slavery and human trafficking statement for the financial year 1 November 2025 to 31 October 2026.

Approved by the Board on 27 November 2025.

Mike Feltham
Chief Executive Officer, Vault Cloud UK Ltd