Modern Slavery and Human Trafficking Statement

Purpose of this Statement

This statement (the “Statement”) is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) on behalf of CYPFER. Recorded in the Statement are the actions taken by CYPFER during 2023 to ensure that modern slavery and human trafficking do not take place within its supply chain and are not associated with its business operations.

This Statement has been approved by Ed Dubrovsky, COO and Managing Partner of CYPFER, on December 1, 2023.

Our Commitment

CYPFER is committed to maintaining the highest professional standards and “doing the right thing” in all aspects of our business. This commitment is reflected in our efforts to combat modern slavery and human trafficking within our supply chains.

In anticipation of the proposed amendment to the Act in 2020, which requires statements to include information on six areas, we have outlined our response to each of these areas below.

1. Our Structure, Business, and Supply Chains

CYPFER specializes in cybersecurity services, operating through offices and subsidiaries globally, including in Canada, the United States, Singapore, the United Kingdom, and other strategic locations.

We are dedicated to eliminating any possibility of slavery in our supply chain. CYPFER’s supply chain is straightforward, primarily consisting of professional services and information technology procurement. The sourcing and purchasing of goods and services are managed by our executive team under the guidance of our Chief Financial Officer.

2. Our Policies

In addition to this Modern Slavery and Human Trafficking Statement, CYPFER has a range of policies available to our team members, including our Code of Conduct and Security Policies. These policies address ethics, non-discrimination, anti-harassment, and anti-bribery/anti-corruption/anti-money laundering.

3. Our Due Diligence Procedures

CYPFER reviews all suppliers using a risk-based approach upon onboarding and regularly thereafter. This assessment considers factors such as the location of service or goods provision, industry sector, and specific labor practices of the supplier’s industry and location. This assessment commenced in the second quarter of 2023 and will conclude by the second quarter of 2024.

We plan to implement a contract management process in 2024, requiring new suppliers to provide evidence of their modern slavery and human trafficking policies.

4. Risks of Slavery or Human Trafficking in Our Supply Chain and Business

While we view the provision of cybersecurity services as low risk for human trafficking and slavery, we remain vigilant. Certain areas, such as transactions on the dark web or involving cryptocurrency, are known to pose higher risks. For these areas, we have established reporting requirements to ensure proper documentation and, if necessary, coordination with relevant authorities.

5. Effectiveness Measured Against Performance Indicators

CYPFER continues to enhance systems to ensure that our business and supply chain are free from modern slavery. In line with UK Government guidance, our executive team will review the following key performance indicators:

– The number of reported suspicions of slavery;

– Compliance with policies and training metrics among employees;

– Responses from suppliers during due diligence processes.

CYPFER is committed to upholding and promoting human rights through our business practices.

6. Training and Capacity Building

We provide our team members with additional resources regarding modern slavery and human trafficking through our Human Resources department.

Looking Ahead

CYPFER will regularly assess the risk of modern slavery and human trafficking in our supply chain, both from existing and new suppliers, to ensure ongoing vigilance and improvement in this critical area.within our control and on our premises, you should be aware that no method