Anti Slavery Policy

Anti-slavery and Human Trafficking Statement

Railston and Company Limited is committed to maintaining and improving practices to combat slavery and human trafficking. As a responsible, ethical and leading member of the global software industry we demonstrate our commitment to social and environmental responsibility.

Company Overview

We are a UK software and services company selling a SaaS Inspection & Maintenance Platform for organisations that use teams of Field Service Professionals.

Due diligence processes for slavery and human trafficking

We are currently reviewing our systems to identify and assess potential risk areas in our supply chains and based on our review we will put in place or strengthen our systems to:

• mitigate the risk of slavery and human trafficking occurring in our supply chains;

• monitor potential risk areas in our supply chains; and

• protect whistle

Railston and Company is formulating an updated supplier due diligence process for on-boarding suppliers based in higher risk territories and industries, and we are considering a risk-based questionnaire based on the UN Global Compact’s Ten Principles in the areas of human rights, labour, environment and anti-corruption. Railston and Company explicitly seeks to do business with suppliers that mirror our values in relation to those topics. Our initial focus is with those suppliers in industries and territories who are identified as higher risk. We are currently formulating our approach on how best to engage with these suppliers.

Staff Training

All relevant UK staff have been briefed on the provisions of the Act, and our obligations and compliance measures, and we will continue both annual updates and more specialised training for our procurement team as we develop our measures.

Following a review of the effectiveness of the steps we are taking to ensure that the risk of slavery or human trafficking in our supply chains is understood and minimised, we intend to continue on our journey to further combat slavery and human trafficking.

These efforts, as well as this disclosure, are reviewed by the Railston and Company Limited Senior Management Team annually and updated publicly.

Our effectiveness in combating slavery and human trafficking

We strive to ensure that we do not contribute towards slavery and human trafficking or other adverse human rights impacts through our supply chains. We intend to only engage those suppliers that comply with our values and Principles of Social Responsibility. In the event that suppliers fail to provide assurance to cease or prevent slavery and human trafficking or other adverse human rights impacts, we will consider terminating our business relationships with those suppliers.

In order to minimise any risk of modern slavery and human trafficking in our supply chains, we are taking various actions including requesting existing suppliers to respond to an anti-slavery questionnaire as well as conducting relevant screening on potential new suppliers. Currently,100% of the suppliers that responded to the anti-slavery questionnaire indicated that there is no existing conduct of modern slavery and human trafficking in their business activities. In addition, we established internal rules that define the process for conducting investigation and audit on suppliers in order to minimise the risk of modern slavery and human trafficking. Based on such process, we audited some of our suppliers and such suppliers took corrective action in accordance with our instructions.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (a UK Act of Parliament) and constitutes our slavery and human trafficking statement for the financial year ended 30 September 2021.