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Modern Slavery Statement

Revised October 30, 2025

This modern slavery statement has been prepared in accordance with section 54(1) of the Modern Slavery Act 2015 (Statement).

1. Introduction

This Statement is made by Shift Technology UK Limited (Shift, we, our or the Company) for the financial year ending 2024. It sets out the steps we have taken and will take to prevent modern slavery and human trafficking in our business and supply chains. This statement applies to all entities within the Group that are required to report under the Modern Slavery Act 2015.

Shift is a software-as-a-service (SaaS) provider headquartered in Paris, France. We provide intelligent AI solutions for the global insurance industry in France, Spain, Germany, UK, Canada, USA, Mexico and Singapore. Our corporate structure includes 12 legal entities and 504 employees globally.

2. Our supply chains

Our supply chains include suppliers of:

  • Cloud and hosting services,
  • Software and platform vendors,
  • Professional services and consultancy,
  • Office facilities and IT hardware,
  • Marketing, recruitment and outsourced business services.

Most of our direct suppliers are located in the EU and the United States, with some services and goods sourced globally, including regions with elevated modern slavery risk.

3. Our policy on modern slavery

We have a zero-tolerance approach to modern slavery. Our key policies include:

  • Modern Slavery Policy (this statement sits alongside that policy);
  • Code of Conduct and Supplier Code of Conduct (requires suppliers to adhere to ethical labour standards); and
  • Whistleblowing Policy.

These policies are available to employees via our internal intranet and are included in onboarding documentation. Suppliers are required to confirm compliance with our Supplier Code of Conduct.

4. Due diligence processes

We use a risk-based approach to identify and assess modern slavery risk:

  • Supplier onboarding: all new suppliers undergo screening which includes identity checks and basic compliance verification. High-risk suppliers (based on geography, sector, labour intensity or subcontracting practices) are subject to enhanced due diligence.
  • Contract clauses: our standard supplier contracts include clauses requiring compliance with labour and human rights laws and allow audits or evidence of compliance where appropriate.
  • Periodic review: material suppliers are reviewed periodically for compliance and performance.
  • Recruitment contractors: we require partner recruitment agencies

5. Risk assessment and mitigation

We assess risk across:

  • Geography: suppliers or sub-suppliers operating in jurisdictions with higher prevalence of forced labour risks;
  • Industry: suppliers in sectors known for labour risks (manufacturing, logistics, cleaning, etc.);
  • Process: use of temporary agency labour, subcontracting layers, or informal workforce.

Mitigations we apply include:

  • Supplier questionnaires and evidence requests (e.g., payroll, worker contracts, policies);
  • Code of Conduct and contractual obligations requiring corrective action plans;
  • Replacing suppliers who fail to remediate material non-compliance;
  • Prioritising procurement from accredited or audited vendors.

6. Training and awareness

We provide training to relevant staff on modern slavery risks and our obligations, including:

  • Mandatory awareness training for procurement, HR, legal and vendor-facing teams;
  • Specific guidance for managers and recruiters on identifying risks and reporting concerns;
  • Whistleblower channels promoted internally for confidential reporting.

7. Effectiveness and performance indicators

To measure effectiveness of our actions, we track metrics including:

  • Number of training sessions delivered and percentage of target staff trained;
  • Reports received through whistleblowing channels related to labour concerns and outcomes.

8. Reporting concerns and remediation

Employees, suppliers, contractors and third parties can raise concerns confidentially through one of the following channels:

Reporting Option

Link/Contact Details

Vault Platform (App Store)

 App store QR code

Vault Platform (Google Play Store)

 Google Play QR code

Vault Platform

 Vault Platform QR code

Open Reporting on the web

https://app.vaultplatform.com/shifttechnology/open-reporting

Compliance Department

compliance@shift-technology.com

We investigate all reports promptly and objectively. Where we identify modern slavery or labour rights violations, we expect suppliers to remediate. For material or persistent breaches we will suspend or terminate relationships and, if appropriate, notify authorities and support remediation for affected workers.

9. Next steps and continuous improvement

We commit to:

  • Expanding supplier risk coverage and frequency of reviews;
  • Enhancing contract terms and remediation timelines for high-risk suppliers;
  • Increasing accessibility of training and embedding modern slavery checks in procurement workflows;
  • Conducting targeted audits for priority suppliers where risk warrants further verification;
  • Incorporating modern slavery risk into our sustainability and procurement strategy.

10. Approval and publication

This statement has been approved by the Board of Shift Technology UK Ltd and is signed on its behalf

by:

Name: Jeremy Jawish
Title: CEO
Date: 03 November 2025 | 13:45 PST