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Modern Slavery Statement

Lumivero, LLC Modern Slavery Statement

Financial Year Ending December 31, 2025

This statement is published by Lumivero, LLC (along with its subsidiaries and affiliates, “Lumivero”) in accordance with:

  • Section 54(1) of the UK Modern Slavery Act 2015
  • The California Transparency in Supply Chains Act of 2010
  • The Australian Modern Slavery Act 2018 (Cth)1

It outlines the steps Lumivero has taken during the 2025 financial year to prevent modern
slavery and human trafficking in our operations and supply chains.

Our Business

Lumivero is a global software company offering decision-support and data-analytics solutions. We are headquartered in the United States and operate globally, including in the United Kingdom, Australia, France, and Germany.

Our Commitment

Lumivero is committed to conducting business with integrity and in full compliance with all applicable laws. We have a zero-tolerance approach to modern slavery and human trafficking.

Our Supply Chains

Our supply chains primarily involve:

  • Technology vendors
  • Software service providers
  • Professional services firms
  • Business support providers

We consider the risk of modern slavery within our operations and supply chains to be low; however, we remain proactive in identifying, evaluating, and addressing any potential risks. We acknowledge that certain risk areas may exist, including reliance on third-party service providers and lowered visibility into subcontracting arrangements within the supply chain.

Policies and Controls

We maintain internal policies and processes that reflect our values, including:

  • A comprehensive code of conduct within our associate handbook
  • Supplier obligations built into vetting and contracting
  • Employment practices that comply with relevant labor laws

Risk Management and Due Diligence

Our risk management practices include:

  • Screening suppliers where appropriate
  • Engaging with suppliers to address identified issues where appropriate
  • Including anti-slavery provisions in relevant contracts
  • Internal reporting mechanisms for any concerns
  • Investigating any reported concerns relating to labor practices within our operations or supply chain
  • Requiring by contract full legal compliance from vendors

Training and Awareness

We promote awareness among staff involved in procurement and supplier oversight. These individuals are provided with guidelines to help recognize and respond to signs of modern slavery and human trafficking.

Effectiveness and Performance Indicators

Lumivero measures the effectiveness of our efforts to combat slavery and human
trafficking through:

  • Tracking incident reports
  • Assessing supplier adherence to obligations
  • Regularly reviewing and updating our policies to reflect best practices and legal requirements


Ongoing Commitment

Lumivero is committed to ongoing evaluation and enhancement of our policies and processes to ensure continued compliance and ethical practices across all jurisdictions in which we operate.

Consultation

In preparing this statement, Lumivero consulted with relevant stakeholders across its subsidiaries and controlled entities to ensure a consistent and coordinated approach to identifying and addressing modern slavery risks throughout the organization.

Board Approval

This statement has been reviewed and approved by the Board of Directors of Lumivero,
LLC.

Signed:

Gareth Morrison
CEO and Director

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