Modern Slavery Statement

1. About this statement

This statement is made by Arsenale Limited ("Arsenale", "we", "us") and describes the steps we take to identify, prevent, and address modern slavery and human trafficking risks in our own operations and supply chains.

Arsenale's annual turnover does not yet meet the £36 million threshold under section 54 of the Modern Slavery Act 2015, and we are therefore not legally required to publish this statement. We publish it voluntarily because:

• Our intended customers in UK government, defence, regulated finance, and critical national infrastructure expect a published modern slavery statement as part of supplier due diligence, regardless of supplier size.
• Doing the work to publish a substantive statement now — rather than waiting until it becomes mandatory — forces us to design our supplier onboarding and internal procedures around it from day one.
• Transparency on supply chain risk is consistent with the wider posture we set out at arsenale.ai/trust.

This statement is structured against the six areas suggested by section 54(5) of the Modern Slavery Act 2015 and the Home Office's Transparency in Supply Chains: A Practical Guide. It will be reviewed and re-published annually, with the next refresh due no later than 14 May 2027.

2. Our business and structure

Arsenale Limited is a UK private company limited by shares, registered in England and Wales (Company No. 17126962), with its registered office at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ. The company is independently held and is not part of a group required to publish a consolidated statement.

Arsenale designs and supplies an on-premise AI inference appliance (the "Arsenale Appliance") and an associated sovereign-deployment software platform. The appliance is shipped to customers in the United Kingdom; the software is engineered in the United Kingdom. Operations are UK-domiciled.

At the date of this statement Arsenale has one Director and no employees. Where work is performed by external consultants or contractors, those engagements are governed by written agreements that include the policy commitments set out in section 4 below.

3. Our supply chains

Our supply chains are deliberately short and we keep visibility of them at the supplier level. There are five categories.

The category with the highest inherent risk is Hardware, because the global electronics supply chain has documented modern-slavery exposure at the raw-material extraction and component-assembly tiers, particularly beyond Tier 1. Mitigations are described in sections 5 and 6.

4. Policies

Arsenale operates a zero-tolerance position on modern slavery, human trafficking, forced or compulsory labour, child labour, and debt bondage — in our own operations and within any supplier's operations to the extent we can influence them.

This position is given effect by the following internal documents:

• Engineer Day-One Briefing — every person engaged by Arsenale (employee, consultant, or contractor) is taken through a written briefing covering information security, ethical conduct, and modern-slavery awareness, and signs an acknowledgement.
• Standard purchase-order terms — we are introducing a flow-down clause requiring Tier-1 suppliers to confirm compliance with applicable anti-slavery and anti-trafficking laws in their operating jurisdiction, and to make their own published modern-slavery statement available on request.
• Engagement agreements (NDA, consultancy, employment) — our standard templates include conduct provisions and a route for confidential reporting.

We do not yet operate a stand-alone written Anti-Slavery Policy as a separate document; the commitments above are consolidated within the existing framework. A dedicated policy will be issued as the company grows, no later than first headcount expansion beyond the founding Director.

5. Due diligence

Our due diligence approach reflects the company's current scale. It is built around supplier choice rather than supplier audit, on the basis that the most effective control at our size is to source from suppliers whose own MSA posture is already published and verifiable.

5.1 Hardware suppliers

• We prefer suppliers headquartered or manufacturing in jurisdictions with strong labour protections and active modern-slavery legislation (UK, EU, USA, Taiwan, South Korea, Japan).
• Before placing an order with a new hardware supplier, we check whether the supplier publishes a modern-slavery statement, supplier code of conduct, or equivalent disclosure, and we record the URL of that disclosure in our supplier file.
• We do not knowingly source from suppliers with documented, unremediated modern-slavery findings.

5.2 Cloud subprocessors

• All current subprocessors (Cloudflare, Google, Stripe) publish modern-slavery statements that we have reviewed. The current versions are linked from our internal supplier file.
• Subprocessor changes are recorded on the Trust page, and any new subprocessor is screened against the same criteria before engagement.

5.3 Personnel

• Right-to-work checks are performed for all engaged personnel as required by UK immigration law, with documentary evidence retained.
• Standard payment terms are net 30 days or better; we do not impose extended payment terms on individual contractors.
• We do not use unpaid internships, "trial work without pay", or any other arrangement that would substitute for waged labour.

6. Risk assessment

The Director conducts an annual review of modern-slavery risk in Arsenale's operations and supply chain. The review takes account of:

• Changes to the supplier base since the previous review.
• The Home Office's published list of high-risk sectors and geographies.
• Any modern-slavery incidents reported in the public domain involving our existing suppliers.
• Changes to UK or international anti-slavery legislation.

The current assessment identifies Tier-2 and Tier-3 hardware component supply as the area where Arsenale has the least visibility and therefore the greatest residual risk. Given our current order volume, our practical leverage at those tiers is limited; mitigation rests on Tier-1 supplier selection and on the published disclosures of those Tier-1 suppliers. As order volume grows we will introduce direct supplier questionnaires for Tier-1 suppliers and request supplier-of-supplier visibility where available.

7. Effectiveness and key indicators

At our current scale we measure effectiveness against a small number of objective indicators:

These indicators will expand as the company grows. We are deliberate about not publishing KPIs we cannot meaningfully measure at our current scale.

8. Training

Modern-slavery awareness is currently delivered through:

• Director-level — the Director maintains awareness through annual review of the Home Office Transparency in Supply Chains: A Practical Guide and the relevant guidance issued by the Independent Anti-Slavery Commissioner.
• Engaged personnel — the Engineer Day-One Briefing includes a modern-slavery awareness section and the reporting route described in section 9, and is acknowledged in writing.

As headcount expands we will introduce annual refresher training and a dedicated modern-slavery e-learning module aligned with the Home Office's published material.

9. Reporting concerns

Anyone who suspects modern-slavery practices in Arsenale's own operations or in any part of our supply chain is encouraged to report the concern. There are three routes:

• Directly to Arsenale — by email to contact@arsenale.ai. Reports may be made on a confidential or named basis. Reports made in good faith will not result in detriment to the reporter, regardless of whether the underlying concern is substantiated.
• UK Modern Slavery & Exploitation Helpline — 0800 0121 700 (operated by Unseen UK on behalf of the Home Office, available 24 hours).
• Crimestoppers — 0800 555 111 (anonymous).

If a report is made directly to Arsenale, we commit to acknowledge receipt within 5 business days and to provide an initial response within 14 days. Where a report concerns conduct that may also be a criminal offence, we will support and, where appropriate, encourage referral to the relevant law-enforcement authority.

10. Approval and sign-off

Procurement teams may request a counter-signed PDF version of this statement for their records by writing to contact@arsenale.ai.