Modern Slavery Act Statement

01. Introduction & Corporate Identity

This Modern Slavery Act Statement ("Statement") is made pursuant to Section 54 of the Modern Slavery Act 2015 by KHODSHIMA SUMN ASSIST LTD ("Company", "we", "us", or "our"), a private limited company incorporated in England and Wales under company registration number 17435961, with its registered office at 128 City Road, London, United Kingdom, EC1V 2NX.

This Statement sets out the steps the Company has taken during the relevant financial year to ensure that modern slavery, forced labour, child labour, and human trafficking are not taking place in any part of our business or supply chains. Modern slavery is a crime and a violation of fundamental human rights. The Company is committed to acting ethically and with integrity in all business dealings and relationships.

02. Organisational Structure & Business Model

The Company is a small private limited company registered in England and Wales. We provide one-time, non-recurring IT engineering services — specifically Linux server hardening, web stack security configuration, digital shell scripts, security audit assessments, and infrastructure configuration deliverables — to clients worldwide through our website (khodshimasumnassistltd.com).

Business characteristics relevant to modern slavery risk:

• No Physical Supply Chain: The Company does not manufacture, import, or distribute physical goods. Our deliverables are entirely digital (scripts, configuration files, audit reports);
• No Manufacturing: No factories, assembly lines, or production facilities;
• Small Workforce: The Company operates with a small team of IT engineering professionals, all engaged under UK employment contracts or as independent contractors subject to UK law;
• Remote Service Delivery: Services are delivered remotely via ephemeral SSH access (Ed25519 keys) to client servers. No physical labour or on-site work is involved;
• Payment Providers: All payments are processed via Stripe and Airwallex, both of which maintain their own modern slavery and ethical sourcing policies;
• Digital Tooling: The Company uses standard software development tools, cloud infrastructure, and open-source security frameworks (CIS Benchmarks, Lynis). No goods are sourced from factories or regions with high modern slavery risk.

03. Definition of Modern Slavery

For the purposes of this Statement, "modern slavery" encompasses the following concepts as defined under the Modern Slavery Act 2015:

• Slavery (s.1 MSA 2015): The status or condition of a person over whom any or all of the powers attaching to the right of ownership are exercised;
• Servitude (s.1 MSA 2015): The obligation to provide services to another under coercion;
• Forced or Compulsory Labour (s.1 MSA 2015): Exact work or service from any person under the menace of any penalty and for which the person has not offered themselves voluntarily;
• Human Trafficking (s.2 MSA 2015): Arranging or facilitating the travel of another person with a view to exploitation;
• Child Labour: The employment of children in work that is mentally, physically, socially, or morally dangerous and harmful, or that interferes with their education.

The Company recognises that modern slavery can occur in any industry and any geography. While our digital-only business model presents inherently low risk, we remain vigilant and committed to zero tolerance.

04. Supply Chain Due Diligence

The Company's "supply chain" consists primarily of:

• Cloud Infrastructure Providers: Server hosting and DNS providers used for the Company's own website and internal operations. These are large, reputable, UK/US/EU-based corporations subject to their own Section 54 obligations;
• Payment Service Providers: Stripe and Airwallex, both PCI-DSS Level 1 certified and subject to UK regulatory oversight. Each maintains published modern slavery statements;
• Software & Open-Source Tools: Development tools, security frameworks (CIS, Lynis, OWASP), and SaaS platforms. These are digital products with no physical labour component;
• Professional Services: Legal, accounting, and administrative services procured from UK-based regulated professionals.

Due diligence measures applied:

1. Supplier Assessment: Before engaging any supplier, the Company conducts a basic assessment of the supplier's reputation, jurisdiction, and modern slavery posture. Suppliers in high-risk jurisdictions or industries are avoided;
2. Contractual Requirements: Where practicable, the Company includes anti-slavery clauses in supplier contracts requiring compliance with the Modern Slavery Act 2015;
3. Periodic Review: The Company reviews its supplier relationships annually to identify any emerging modern slavery risks;
4. Escalation: If modern slavery is suspected in any part of the supply chain, the Company will terminate the relationship immediately and report to the relevant authorities, including the Modern Slavery Helpline (08000 121 700) and UK law enforcement.

05. Internal Policies & Controls

The Company maintains the following internal policies and controls to prevent modern slavery within our own operations:

• UK Employment Law Compliance: All employees and contractors are engaged under written contracts compliant with the Employment Rights Act 1996, National Minimum Wage Act 1998, and Working Time Regulations 1998. The Company verifies the right to work in the UK for all personnel;
• Zero Tolerance Policy: The Company maintains a zero-tolerance approach to modern slavery, forced labour, child labour, and human trafficking in any form;
• Whistleblowing: Personnel are encouraged to report any concerns about modern slavery or ethical violations without fear of retaliation. Reports can be made to info@khodshimasumnassistltd.com or directly to the Modern Slavery Helpline;
• Training: All personnel receive awareness training on the Modern Slavery Act 2015, including how to identify and report signs of modern slavery;
• Prohibited Activities: The Company refuses to provide services to clients engaged in human trafficking, forced labour, or any activity involving the exploitation of persons. This is enforced through our KYC & AML Policy and Terms & Conditions;
• Sanctions Screening: Clients are screened against UK, UN, EU, and US sanctions lists, which include individuals and entities designated for human rights violations including modern slavery.

06. Risk Assessment & Effectiveness

The Company assesses modern slavery risk across two dimensions:

• Operational Risk (Internal): Low. The Company operates entirely in the digital services sector with a small UK-based workforce engaged under UK employment law. No physical labour, no manufacturing, no operations in high-risk jurisdictions;
• Supply Chain Risk (External): Low. The supply chain consists of digital tools, cloud infrastructure, and professional services from reputable UK/US/EU-based providers. No physical goods are sourced. Payment providers (Stripe, Airwallex) maintain their own robust modern slavery compliance programmes.

Effectiveness of measures: Given the digital-only nature of the business, the small workforce, and the absence of physical supply chains, the Company assesses the risk of modern slavery occurring within its operations or supply chains as negligible. Nevertheless, the Company remains vigilant and committed to continuous improvement.

07. Prohibited Activities & Client Screening

Consistent with our Terms & Conditions and KYC & AML Policy, the Company refuses to provide services to any client engaged in:

• Human trafficking or people smuggling;
• Forced labour or debt bondage operations;
• Child exploitation or child labour facilitation;
• Any activity involving the coercion or exploitation of persons;
• Financial services, cryptocurrency, gambling, or adult content — industries with elevated modern slavery and human trafficking risk profiles;
• Any operation in a sanctioned jurisdiction where UK/UN/EU/US sanctions include human rights grounds.

Client screening is conducted through KYC procedures, sanctions list checks, and order-level review. Where a client is identified as being involved in modern slavery or human trafficking, the Company will refuse the Order, terminate any active license, and report the matter to UK law enforcement and the Modern Slavery Helpline.

08. Review, Reporting & Approval

This Statement is reviewed annually and updated as necessary to reflect changes in the Company's operations, supply chain, or regulatory requirements. The Statement is approved by the Company's board of directors and published on the Company's website in accordance with Section 54(4) of the Modern Slavery Act 2015.

Reporting concerns: Any person who suspects modern slavery in connection with the Company's operations or supply chain should report it to:

• The Company: info@khodshimasumnassistltd.com;
• The Modern Slavery Helpline: 08000 121 700 (24/7, free, confidential);
• UK Police: 999 (emergency) or 101 (non-emergency);
• Crimestoppers: 0800 555 111 (anonymous).