MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2025-26

Version 1.0 · Effective 2 November 2026

Introduction

This statement describes the steps that ECOFACTOR TECH UK LIMITED (“ECOFACTOR UK”, “we”, “us”) has taken to understand and address the risk of modern slavery and human trafficking in its business and supply chains. It covers the company’s first financial year, which began on incorporation on 22 April 2025 and ended on 30 April 2026.

The company’s turnover for that financial year was below the £36 million threshold set by the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015. ECOFACTOR UK is therefore not required to publish a statement under section 54 of the Modern Slavery Act 2015. This statement is published voluntarily, following the structure recommended in section 54(5) and in the Home Office statutory guidance “Transparency in supply chains: a practical guide”.

In this statement, “modern slavery” means slavery, servitude, forced or compulsory labour and human trafficking, as described in sections 1 and 2 of the Modern Slavery Act 2015.

We do not accept modern slavery or human trafficking in our business or in our supply chains. As this is our first statement, it describes both the arrangements in place during the financial year and the steps we are taking next. We will report on our progress in future statements.

1. Our organisation structure and business

ECOFACTOR TECH UK LIMITED is a private company registered in England and Wales under company number 16400124, with its registered office at 86-90 Paul Street, 3rd Floor, London EC2A 4NE. Its directors are Scott Edy and Sergii Velchev. Sergii Velchev, the founder of ECOFACTOR, holds more than 75% of its shares and is registered as its person with significant control.

ECOFACTOR UK is one of the companies operating under the ECOFACTOR brand. The other companies include ECOFACTOR Sp. z o.o. in Poland and ТОВ «ЗАРЯДНІ МЕРЕЖІ» (CHARGING NETWORKS LLC) in Ukraine. Across the ECOFACTOR group, the companies design and manufacture electric vehicle (EV) charging hardware, develop and operate a charge point management system (CPMS), operate public charging networks and provide installation, maintenance and related services. Hardware assembly takes place principally in Poland, with research and development and supplementary production in Ukraine.

In the United Kingdom, ECOFACTOR UK:

• supplies and delivers EV charging infrastructure projects using ECOFACTOR hardware and software;
• takes part in public-sector procurement, including local authority tenders;
• arranges installation and maintenance through accredited installation and maintenance partners (“delivery partners”);
• is preparing the launch of an ECOFACTOR public charging network in the UK.

During the financial year ECOFACTOR UK operated with a small team in the United Kingdom, led by its UK director and supported by colleagues employed by other ECOFACTOR companies.

2. Our supply chains

Category	What it covers	Main locations
EV charging hardware	AC and DC charging equipment supplied by ECOFACTOR group companies	Poland (assembly); Ukraine (supplementary production)
Components and materials (lower tiers)	Electronic assemblies, power electronics, enclosures, cabling and other components bought by the group’s manufacturing operations	EU and international suppliers
Software and technology	CPMS development and support, systems integration, cloud hosting and IT services	Ukraine and Poland (ECOFACTOR software teams); cloud and IT service providers in the EU, the UK and the USA
Installation and maintenance	Civil, electrical and installation works and ongoing maintenance carried out by accredited delivery partners and their subcontractors	United Kingdom
Professional and business services	Legal, accounting, advisory, office and administrative services	United Kingdom and EU

3. Our policies

During the financial year, ECOFACTOR UK prepared an internal policy framework (June 2025) covering anti-bribery and corruption, a code of conduct, whistleblowing, conflicts of interest, human rights, employment, health and safety, data protection and responsible sourcing.

After the end of the financial year, together with approving this statement, the board of directors adopted the following ECOFACTOR group policies for the company. They are published on our website:

• Code of Conduct — the standards of behaviour expected of everyone who works for or on behalf of ECOFACTOR, including respect for human rights and fair treatment of workers (https://ecofactortech.com/legal/code-of-conduct/);
• Anti-Bribery and Corruption Statement — our commitment to preventing bribery, which is closely linked to labour exploitation risks in supply chains (https://ecofactortech.com/legal/anti-bribery/);
• Human Rights Policy — our commitment to respect internationally recognised human rights, including freedom from forced labour, child labour and trafficking (https://ecofactortech.com/legal/human-rights/);
• Supplier Code of Conduct — the minimum standards we expect from suppliers, delivery partners and their subcontractors, including that work is freely chosen, that workers are not charged recruitment fees, that identity documents are not withheld and that child labour is not used (https://ecofactortech.com/legal/supplier-code-of-conduct/);
• Report a concern (Speak-up policy) — how workers, suppliers and members of the public can raise concerns, including anonymously, without fear of retaliation (https://ecofactortech.com/legal/report-a-concern/).

4. Due diligence

During the financial year. Our due diligence during our first year was proportionate to an early-stage UK business and included:

• direct oversight of the group’s manufacturing operations in Poland by ECOFACTOR group management;
• monitoring the situation in Ukraine through in-country management and credible public sources;
• oversight of works on UK sites by our UK director during projects.

We did not carry out formal supplier questionnaires or supplier audits during the year. The steps below are designed to close that gap.

Next steps. During the year ending 30 April 2027 we intend to:

• ask new significant suppliers and delivery partners to acknowledge the Supplier Code of Conduct or confirm equivalent standards;
• introduce a risk-based supplier questionnaire, with more detailed checks for higher-risk categories and countries;
• include modern slavery provisions in new supplier and delivery-partner contracts, including flow-down to subcontractors, a requirement to tell us about concerns and a right for us to request information or carry out checks;
• work with the group’s manufacturing operations to map lower-tier suppliers in the highest-risk component categories.

Remediation. If we find indications of modern slavery, our first priority will be the safety and welfare of the workers affected. We will work with the supplier concerned to put things right and, where appropriate, involve the relevant authorities. We will consider ending a business relationship where a supplier is unwilling to address serious issues.

5. Risk assessment

We have identified the following areas as presenting the highest modern slavery risk in our business and supply chains.

Area	Why we see a risk	How we manage it
Operations in Ukraine	R&D and supplementary production take place in a country affected by armed conflict, where displacement and economic pressure can increase workers’ vulnerability.	Direct management engagement by group management; regular review of operations in Ukraine, with the safety and welfare of workers as the primary consideration.
Lower-tier component supply chain	We have limited direct visibility of suppliers below the first tier. Electronics manufacturing and the extraction and processing of metals are recognised internationally as sectors with elevated modern slavery risk.	Supplier Code of Conduct; risk-based supplier questionnaires; mapping of lower-tier suppliers in the highest-risk categories, starting in the year ending 30 April 2027.
Installation subcontracting in the UK	Installation and civil works rely on delivery partners who may engage subcontractors and labour providers. Construction and related trades are recognised as sectors with elevated risk of labour exploitation in the UK.	Use of accredited delivery partners; contractual requirements to comply with the law and flow requirements down to subcontractors; requirement to tell us about concerns; oversight of works on site by our UK team during projects.

We consider the risk in our own direct UK workforce to be low, given its size and the roles involved.

6. Training

During the financial year: no formal modern slavery training was delivered.

Next steps: we intend to provide modern slavery awareness training to all UK staff at induction, more detailed training for staff involved in procurement, tenders and project delivery, and a briefing for our delivery partners on our Supplier Code of Conduct.

7. Measuring effectiveness: targets for the year ending 30 April 2027

As this is our first statement, we have not yet measured performance against indicators. We have set the following targets for the next financial year and will report against them in our next statement.

Indicator	Target for the year ending 30 April 2027
New significant suppliers and delivery partners that have acknowledged the Supplier Code of Conduct or confirmed equivalent standards	100%. A “significant” supplier is one with expected annual spend above £25,000 or that carries out work on site for us
New supplier and delivery-partner contracts containing modern slavery provisions	100%
UK staff completing modern slavery awareness training within 30 days of joining	100%
Highest-risk lower-tier component categories mapped	At least the two highest-risk categories (power electronics and cabling)
Concerns about modern slavery reported to us that are acknowledged and assessed	100%, with the number of concerns reported in our next statement
Review of modern slavery risk in operations in Ukraine	Completed at least once during the year

8. Reporting a concern

Anyone with a concern about modern slavery or human trafficking connected with ECOFACTOR can contact us at info@ecofactor.eu or use our Report a concern page (https://ecofactortech.com/legal/report-a-concern/). Concerns can be raised anonymously. We do not tolerate retaliation against anyone who raises a concern in good faith.

Concerns can also be reported to the Modern Slavery and Exploitation Helpline on 08000 121 700. If someone is in immediate danger, call 999.

9. Approval

This statement was approved by the board of directors of ECOFACTOR TECH UK LIMITED on 2 November 2026. It will be reviewed and updated annually, and our next statement will cover the financial year ending 30 April 2027.

Signed for and on behalf of the board of directors of ECOFACTOR TECH UK LIMITED:

Field	Details
Name	Scott Edy
Position	Director
Signature	Signed electronically: Scott Edy
Date	2 November 2026

Document control

Version	Date	Owner	Approved by
1.0	2 November 2026	Director, ECOFACTOR TECH UK LIMITED	Board of directors of ECOFACTOR TECH UK LIMITED