Modern Slavery and Human Trafficking Statement

1. About QED

1. 1.1.

   QED Ltd is a software development and AI technology company with entities in Croatia, Serbia and the UK. We design and build bespoke software, data solutions, and AI products for clients across various sectors.

2. 1.2.

   QED employs people in the United Kingdom, Croatia and Serbia, through QED Ltd, QED d.o.o. and QED Tech d.o.o. respectively. QED also works with software developers in Latin America and the Philippines. All of them are engaged through an employer-of-record provider, which employs them full-time through its local entities. This is the part of our workforce that carries the higher labour rights risk, and it is the part our due diligence concentrates on.

3. 1.3.

   Our direct exposure is assessed as low given the nature of our work, but risks exist in our broader supply chain and we remain vigilant.

2. Our Supply Chain

QED's supply chain is relatively simple and predominantly consists of:

1. •

   Technology vendors and SaaS providers (e.g., cloud infrastructure, development tools, HR systems)

2. •

   Professional services firms (legal, accountancy, HR)

3. •

   Freelance contractors and sub-contractors in the technology sector

Our highest risk categories are assessed as:

1. •

   hardware procurement (potential conflict minerals / manufacturing conditions)

2. •

   offshore development sub-contracting

3. Policies in Relation to Slavery and Human Trafficking

QED maintains the following policies relevant to preventing modern slavery:

1. •

   This Modern Slavery Statement

2. •

   ESG Policy (including supply chain ethics and ethical client selection)

3. •

   General Data Protection Policy

4. •

   Employee Privacy Notice

5. •

   Code of Conduct Policy

6. •

   Whistleblowing Policy

All employees and contractors are required to read and acknowledge our Code of Conduct Policy, which explicitly prohibits participation in or facilitation of modern slavery, forced labour, child labour, or human trafficking in any form.

4. Due Diligence Processes

To identify and address risks of modern slavery and human trafficking, QED takes the following steps:

1. 4.1.
   Employment Practices

   1. 4.1.1.

      All QED employees are engaged on written contracts at or above the statutory minimum wage (UK National Minimum Wage and National Living Wage; Croatian and Serbian statutory minimums). Developers in Latin America and the Philippines are employees of that provider's local entities, which run their payroll, taxes and statutory benefits under local employment law, including the local minimum wage. Their pay is set at market rates for skilled software engineers, well above those minimums.

   2. 4.1.2.

      Right-to-work checks are conducted for all employees before commencement of employment.

   3. 4.1.3.

      We do not charge fees to workers for employment, accommodation, or equipment.

   4. 4.1.4.

      We do not hold workers' identity documents.

2. 4.2.
   Supply Chain

   We prefer suppliers with published Modern Slavery Statements or equivalent commitments.

3. 4.3.
   Reporting & Concerns

   1. 4.3.1.

      Any employee, contractor, or third party who suspects modern slavery or human trafficking in connection with QED's business or supply chain should report it immediately to the COO at compliance@qedcode.io.

   2. 4.3.2.

      Reports can also be made to the relevant authorities: the Modern Slavery Helpline (UK: 08000 121 700) or the National Crime Agency.

5. Training

1. 5.1.

   QED does not run formal modern slavery training. Every employee and every developer working on QED projects reads and acknowledges the Code of Conduct Policy at onboarding, which prohibits modern slavery, forced labour, child labour and human trafficking.

2. 5.2.

   Staff who choose suppliers or recruit are expected to watch for the warning signs of modern slavery and to raise any concern with the COO.

3. 5.3.

   Acknowledgement of the Code of Conduct Policy is recorded in Factorial.

4. 5.4.

   All staff are directed to report any concerns to the COO in accordance with clause 4.3.

6. Review of this Statement

1. 6.1.

   Section 54 of the Modern Slavery Act 2015 applies to organisations with a total turnover of £36m or more. QED is below that threshold, so it is under no statutory duty to publish a statement. QED publishes one because clients ask for it and because the exercise is worth doing, and follows the statutory form so that the statement stands up when a client's procurement team reads it.

2. 6.2.

   On that basis this statement is prepared, approved and published for each financial year, within six months of the financial year end, with a link from a prominent place on the QED homepage. Each year's statement is prepared by the COO, approved by the Board and signed by a director, and describes the steps taken during that financial year.

3. 6.3.

   If QED's turnover reaches £36m, publication stops being a choice and the timetable above becomes a legal obligation. The COO checks turnover against the threshold when the annual accounts are prepared. The COO also reviews this statement whenever there is a change in law or regulatory guidance affecting it.

7. Approval

1. 7.1.

   This is the slavery and human trafficking statement of QED Ltd for the financial year stated in the table at the head of this document, published voluntarily in the form set out in section 54 of the Modern Slavery Act 2015. It is a statement, not a policy; the policies it refers to are named in Section 3.

2. 7.2.

   It was approved by the Board of Directors of QED Ltd on 25/09/2026 and is signed below by a director of QED Ltd.

3. 7.3.

   It is published on QED's website at qed.tech/legal/modern-slavery, reached from the homepage through the "ESG Policies" link in the footer.

Signed for and on behalf of QED Ltd:

Name: Jane Ryan

Position: Director

Date: 25/09/2026