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Legal · Cognitiva Systems Inc.

Modern Slavery Statement

MODERN SLAVERY ACT STATEMENT

Cognitiva Systems Inc.
Financial Year: April 2025 – April 2026
Published: 15 April 2026
Approved by Board: 15 April 2026

INTRODUCTION

This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and constitutes Cognitiva Systems Inc.'s ("Cognitiva," "we," "us," or "our") slavery and human trafficking statement for the financial year ending 15 April 2026.

Commitment:
Cognitiva is committed to preventing slavery and human trafficking in our business operations and supply chains. We have zero tolerance for modern slavery in any form.

1. ORGANIZATION STRUCTURE

1.1 Company Overview

Legal Entity:
Cognitiva Systems Inc.
Incorporated in Delaware, United States
Registration Number: Available upon request

Business Activities:

  • Software as a Service (SaaS) platform for campaign management
  • Data infrastructure and anonymized dataset licensing
  • AI-powered decision APIs (Intelligence Platform)

Revenue: Under $5M ARR
Employees: Under 50 full-time
Contractors: Under 25 independent contractors

1.2 Corporate Structure

Subsidiaries: None
Parent Company: None (independent entity)

Geographic Presence:

  • Primary operations: United States
  • Customers: Global (100+ countries)
  • Remote workforce: United States, United Arab Emirates, Saudi Arabia, United Kingdom

1.3 Business Model

Three-Layer Platform:

  1. CognitivaOS (Execution SaaS): Campaign workflow management
  2. Data Infrastructure: Anonymized dataset creation and licensing
  3. Intelligence Platform: ML-powered decision APIs

Revenue Streams:

  • Subscription fees ($200-500/month per agency)
  • API usage fees ($0.05-0.15 per decision)
  • Data licensing (enterprise contracts, $10k+ minimum)

2. SUPPLY CHAINS

2.1 Supply Chain Overview

Cognitiva's supply chain consists primarily of:

Digital Services:

  • Cloud infrastructure providers (AWS, Google Cloud)
  • Payment processors (Stripe)
  • Software development tools and platforms
  • Customer support and communication platforms
  • Security and monitoring services

Professional Services:

  • Legal and compliance counsel
  • Accounting and audit services
  • Marketing and creative agencies
  • Recruitment and HR services

Hardware (Limited):

  • Employee laptops and equipment
  • Office furniture (minimal - remote-first company)

2.2 Geographic Supply Chain

Primary Supplier Locations:

  • United States: 70% of suppliers
  • European Union: 15% of suppliers
  • United Kingdom: 10% of suppliers
  • Other: 5% of suppliers

Risk Assessment:

  • Low risk: Tier 1 suppliers (major tech companies with robust compliance)
  • Medium risk: Tier 2 suppliers (smaller service providers)
  • High risk: Minimal exposure (no manufacturing, no high-risk jurisdictions)

2.3 Supplier Categories

Category A - Cloud Infrastructure (High Spend, Low Risk):

  • Amazon Web Services (AWS)
  • Google Cloud Platform (GCP)
  • Both have published Modern Slavery statements and strong compliance

Category B - SaaS Tools (Medium Spend, Low Risk):

  • Stripe (payment processing)
  • GitHub (code repository)
  • Slack (communications)
  • Notion, Linear (project management)
  • All publicly traded or venture-backed with compliance programs

Category C - Professional Services (Variable Spend, Low-Medium Risk):

  • Law firms (US, EU, UK based)
  • Accounting firms (Big 4 or equivalent)
  • Marketing agencies (vetted for compliance)
  • Freelance contractors (individual due diligence)

Category D - Equipment (Low Spend, Medium Risk):

  • Laptop and hardware suppliers
  • Office equipment vendors
  • Potential supply chain risk in manufacturing

3. POLICIES AND PROCEDURES

3.1 Code of Conduct

Employee Code of Conduct:

All employees and contractors must:

  • Comply with all applicable laws, including anti-slavery legislation
  • Report suspected modern slavery or human trafficking
  • Not engage in any form of forced labor, child labor, or human trafficking
  • Treat all persons with dignity and respect
  • Follow ethical business practices

Consequences:
Violation of Code of Conduct results in disciplinary action up to and including termination and legal referral.

Training:
Annual Code of Conduct training mandatory for all personnel.

3.2 Recruitment and Hiring

Fair Hiring Practices:

✓ No recruitment fees charged to job candidates
✓ No retention of passports or identity documents
✓ Clear employment terms provided before hire
✓ Right to terminate employment without penalty
✓ Voluntary employment only (no forced labor)

Verification:

  • Right to work verification (I-9 for US, equivalent for other jurisdictions)
  • Background checks for security-sensitive roles
  • Age verification (18+ minimum)

Contractor Engagement:

  • Written contracts with clear terms
  • Fair compensation (market rates or above)
  • Freedom to refuse work or terminate relationship
  • No debt bondage or coerced work

3.3 Supplier Code of Conduct

Requirements for Suppliers:

Suppliers must:

  1. Comply with Modern Slavery Act 2015 and equivalent legislation
  2. Not use forced, bonded, involuntary, or child labor
  3. Respect workers' rights to freedom of association
  4. Provide safe and healthy working conditions
  5. Pay at least minimum wage and comply with working hours regulations
  6. Not discriminate or harass workers
  7. Maintain accurate records and allow audits

Contractual Terms:

  • Modern slavery compliance clause in all supplier contracts
  • Right to audit supplier practices
  • Termination rights for non-compliance

New Supplier Onboarding:

  • Modern slavery questionnaire
  • Self-assessment of supply chain risks
  • Certification of compliance with anti-slavery laws
  • Review of supplier's own Modern Slavery statement (if applicable)

3.4 Whistleblowing Policy

Reporting Mechanism:

Employees, contractors, and suppliers can report concerns via:

Protection:

  • No retaliation against good-faith reporters
  • Anonymous reporting options available
  • Investigation of all reports
  • Confidentiality maintained to extent possible

Investigation Process:

  1. Initial assessment within 48 hours
  2. Full investigation if credible
  3. Corrective action if substantiated
  4. Follow-up to prevent recurrence
  5. Annual report to Board on investigations

4. DUE DILIGENCE

4.1 Risk Assessment

Annual Risk Assessment:

We conduct annual risk assessments covering:

Geographic Risk:

  • Supplier locations mapped against modern slavery risk indices
  • High-risk countries flagged for enhanced due diligence
  • Currently minimal exposure to high-risk jurisdictions

Sector Risk:

  • Technology sector: Generally low risk (knowledge work)
  • Hardware supply chain: Medium risk (manufacturing)
  • Professional services: Low risk (regulated professions)

Tier Risk:

  • Tier 1 suppliers: Direct engagement, high visibility, low risk
  • Tier 2+ suppliers: Lower visibility, require supplier attestation
  • Contractors: Individual assessment, documentation of fair terms

Current Risk Profile:
Overall risk: LOW

  • Primary suppliers are major tech companies with strong compliance
  • No manufacturing operations
  • No high-risk geographic exposure
  • Predominantly knowledge-based service model

4.2 Supplier Due Diligence

Tier 1 Suppliers (Direct, High Spend):

✓ Modern Slavery statement reviewed (if applicable)
✓ Questionnaire completed
✓ Certifications obtained (ISO, labor standards)
✓ Contract includes compliance clause
✓ Annual compliance confirmation

Tier 2 Suppliers (Indirect, Lower Spend):

✓ Self-assessment questionnaire
✓ Attestation of compliance
✓ Contract includes compliance clause
✓ Risk-based monitoring

High-Risk Suppliers (if any):

✓ Enhanced due diligence
✓ On-site audits (or third-party audit reports)
✓ Regular monitoring
✓ Contingency plans for alternative suppliers

Current Status:

  • All Tier 1 suppliers assessed: 100% compliant
  • All Tier 2 suppliers assessed: 100% compliant
  • No high-risk suppliers identified

4.3 Contractor Due Diligence

Independent Contractors:

For each contractor engagement:

  • Written agreement with fair compensation terms
  • Verification of voluntary engagement
  • Confirmation of no intermediary exploitation
  • Regular check-ins on working conditions
  • Freedom to terminate without penalty

Freelance Platforms:

  • Use only reputable platforms (Upwork, Toptal, etc.)
  • Verify platform's own labor practices
  • Direct payment to contractors (no withholding)
  • Fair rates (market competitive or above)

5. TRAINING AND AWARENESS

5.1 Employee Training

Modern Slavery Awareness Training:

Target Audience:

  • All employees (annual training)
  • Hiring managers (specialized training)
  • Procurement team (enhanced training)
  • Executive team (strategic oversight training)

Training Content:

  • What is modern slavery and human trafficking
  • Signs and indicators of modern slavery
  • Relevant legislation (MSA 2015, TVPA, etc.)
  • Cognitiva's policies and procedures
  • How to report concerns
  • Consequences of non-compliance

Delivery Method:

  • Online training module (30 minutes)
  • In-person workshops for procurement/HR
  • Annual refresher for all staff
  • New hire onboarding module

Completion Tracking:

  • Training completion tracked in HR system
  • 100% completion required annually
  • Non-completion escalated to management

Current Status:

  • 100% of employees completed training this year
  • Next training cycle: April 2027

5.2 Specialized Training

Procurement Team:

  • Supplier risk assessment methodologies
  • Red flags in supplier relationships
  • Audit techniques
  • Remediation strategies

HR/Recruitment:

  • Fair hiring practices
  • Forced labor indicators in hiring
  • Right-to-work verification
  • Refugee and vulnerable worker protections

Leadership:

  • Strategic oversight of modern slavery risks
  • Board reporting requirements
  • Stakeholder engagement
  • Continuous improvement

6. PERFORMANCE INDICATORS

6.1 Key Performance Indicators (KPIs)

We measure effectiveness through:

Supplier Compliance:

  • % of Tier 1 suppliers assessed: 100%
  • % of Tier 1 suppliers with MS statements: 85%
  • % of suppliers with contractual compliance clause: 100%
  • Number of non-compliant suppliers identified: 0
  • Number of supplier relationships terminated for non-compliance: 0

Training:

  • % of employees completing annual training: 100%
  • % of new hires completing training within 30 days: 100%
  • Number of training sessions conducted: 2

Reporting:

  • Number of modern slavery concerns reported: 0
  • Number of investigations conducted: 0
  • Number of substantiated cases: 0
  • Average investigation completion time: N/A

Risk Assessment:

  • Number of high-risk suppliers identified: 0
  • % of high-risk suppliers audited: N/A
  • Number of audits conducted: 0

6.2 Current Year Performance

April 2025 – April 2026 Results:

KPITargetActualStatus
Tier 1 supplier assessment100%100%✓
Employee training completion100%100%✓
Modern slavery reports-0-
Substantiated cases00✓
Supplier contract clause100%100%✓

Assessment:
This is Cognitiva's first formal Modern Slavery Act statement. All measurable KPIs were met in our inaugural year. As a technology-led, remote-first company with no manufacturing operations, our overall risk profile remains low. Our primary focus going forward is extending due diligence visibility into Tier 2 suppliers and formalising annual training as headcount grows.

6.3 Areas for Improvement

Identified Gaps:

  1. Tier 2 supplier visibility could be improved as vendor count grows
  2. Formal supplier management platform not yet in place — currently managed via contracts and spreadsheets
  3. No third-party audit of practices conducted yet (planned for 2027)

Remediation Plans:

  1. Implement supplier compliance tracking in procurement workflow by Q4 2026 — Ops Lead
  2. Evaluate and adopt supplier management tooling by Q2 2027 — Head of Operations
  3. Engage external compliance advisor for independent review by April 2027 — Legal & Compliance

7. REMEDIATION AND CORRECTIVE ACTION

7.1 Issue Identification

If Modern Slavery Identified:

We take immediate action when modern slavery or human trafficking is identified or suspected in our operations or supply chain.

Response Protocol:

  1. Immediate Suspension: Suspend activity/relationship pending investigation
  2. Victim Support: Ensure affected persons receive appropriate support and resources
  3. Investigation: Conduct thorough investigation (internal or third-party)
  4. Authorities: Report to appropriate authorities as required by law
  5. Remediation: Implement corrective actions
  6. Prevention: Strengthen controls to prevent recurrence

7.2 Supplier Non-Compliance

Graduated Response:

Level 1 - Minor Non-Compliance:

  • Corrective Action Plan required
  • Timeline: 30 days
  • Follow-up assessment
  • Continue relationship if remediated

Level 2 - Moderate Non-Compliance:

  • Immediate Corrective Action Plan
  • Third-party audit required
  • Suspension of new business
  • Timeline: 60 days
  • Termination if not remediated

Level 3 - Severe Non-Compliance:

  • Immediate termination of relationship
  • Report to authorities
  • Notify affected parties
  • Support for victims
  • Public disclosure if material

7.3 Continuous Improvement

Annual Review Process:

  1. Board reviews this statement and performance
  2. Risk assessment updated
  3. Policies and procedures revised as needed
  4. Training materials updated
  5. KPIs adjusted to drive improvement
  6. New statement published

External Benchmarking:

  • Review industry best practices
  • Compare to peer companies' statements
  • Engage with NGOs and experts
  • Participate in industry initiatives

8. COLLABORATION AND ENGAGEMENT

8.1 Industry Collaboration

Partnerships:

  • Tech Against Trafficking (prospective member — application in progress)
  • We actively monitor relevant industry associations and collaborative initiatives as the company scales

Knowledge Sharing:

  • Participate in industry forums
  • Share best practices
  • Contribute to guidance development

8.2 Stakeholder Engagement

Employees:

  • Annual training
  • Open communication channels
  • Whistleblowing protections
  • Feedback on policies

Suppliers:

  • Clear expectations communicated
  • Collaboration on risk reduction
  • Support for improvement efforts
  • Recognition of good practices

Customers:

  • Transparency about our practices
  • Response to customer due diligence requests
  • Alignment with customer values

Civil Society:

  • Engagement with NGOs
  • Support for victim services
  • Advocacy for strong legislation

8.3 Transparency

Public Disclosure:

  • This statement published on website
  • Updated annually
  • Available in multiple languages if requested
  • Accessible to all stakeholders

Reporting:

  • Board receives annual report on modern slavery efforts
  • Executive team monitors KPIs quarterly
  • Audit committee reviews high-risk areas
  • External audit if material risks identified

9. SPECIFIC RISKS AND MITIGATION

9.1 Remote Workforce Considerations

Risk:
Cognitiva operates with predominantly remote workforce across multiple countries. While this reduces traditional workplace risks, it creates challenges in visibility.

Mitigation:

  • Direct employment relationships (no intermediaries)
  • Fair compensation benchmarked to local markets
  • Regular check-ins with distributed team members
  • Clear contracts with terms in local language
  • Local labor law compliance verification
  • Freedom to work from location of choice

Current Status:
No indicators of forced labor or exploitation in remote workforce.

9.2 Contractor and Gig Economy Risks

Risk:
Use of independent contractors and freelancers may involve platform intermediaries that could facilitate exploitation.

Mitigation:

  • Vet platforms for labor practices
  • Direct payment to contractors when possible
  • Fair rates (market competitive or above)
  • No fees deducted from contractor payments
  • Regular communication and feedback
  • Freedom to decline work or terminate engagement

Current Status:
All contractors report voluntary engagement and fair terms.

9.3 Hardware Supply Chain

Risk:
Employee laptops and equipment may have manufacturing supply chains with modern slavery risks.

Mitigation:

  • Prioritize suppliers with Conflict Minerals declarations
  • Choose brands with strong labor practices
  • Purchase from authorized distributors only
  • Require supplier certifications
  • Consider refurbished equipment (extends life, reduces new manufacturing demand)

Current Status:
Hardware procurement volume is low; enhanced due diligence applied.

9.4 Data and AI Ethics

Unique Risk:
As an AI company, we must ensure our AI models are not trained on data obtained through exploitation.

Mitigation:

  • Data provenance tracking for training data
  • Ethical AI principles prohibit exploitative data sources
  • Anonymization protects data subjects
  • Opt-in data contributions (no coercion)
  • Regular ethics review of AI practices

Current Status:
All training data sourced ethically from voluntary platform use.

10. GOVERNANCE AND ACCOUNTABILITY

10.1 Board Oversight

Responsibility:
The Board of Directors has ultimate responsibility for Cognitiva's anti-slavery efforts.

Activities:

  • Annual review of this statement before publication
  • Approval of policies and procedures
  • Review of KPIs and performance
  • Resource allocation for compliance programs
  • Response to material issues or incidents

April 2025 – April 2026 Board Actions:

  • 15 April 2026: Board reviewed and approved this statement
  • 15 April 2026: Board received briefing on modern slavery risks
  • 15 April 2026: Board approved budget for ongoing compliance and due diligence

10.2 Executive Responsibility

Designated Executive:
Head of Legal & Compliance — reporting to the Board

Responsibilities:

  • Day-to-day oversight of anti-slavery program
  • Quarterly KPI reporting to Board
  • Coordination across departments
  • Supplier risk management
  • Incident response
  • Continuous improvement initiatives

10.3 Cross-Functional Team

Modern Slavery Working Group:

Members:

  • Legal & Compliance (lead)
  • Human Resources
  • Procurement
  • Security
  • Operations

Activities:

  • Quarterly meetings
  • Risk assessment updates
  • Policy reviews
  • Training development
  • Incident response

10.4 External Assurance

Independent Review:

  • We plan to engage external compliance advisors for independent assurance in 2027.

Certifications:

  • SOC 2 Type II compliance in progress

11. COMMITMENT AND CONTINUOUS IMPROVEMENT

11.1 Our Commitment

Cognitiva commits to:

✓ Zero tolerance for modern slavery and human trafficking
✓ Continuous improvement of our due diligence processes
✓ Transparency with stakeholders about our practices
✓ Collaboration with industry, government, and civil society
✓ Support for victims if modern slavery is identified
✓ Accountability through measurable performance indicators

11.2 Next Year Priorities

April 2026 – April 2027 Focus Areas:

  1. Enhanced Tier 2 Supplier Visibility:

    • Expand due diligence to sub-suppliers
    • Implement supplier mapping tool
    • Conduct risk-based audits

  2. Training Expansion:

    • Develop role-specific training modules
    • Increase training frequency for high-risk roles
    • Add scenario-based exercises

  3. Technology Solutions:

    • Implement supplier management platform
    • Automate compliance tracking
    • Enhance reporting capabilities

  4. Industry Leadership:

    • Join Tech Against Trafficking
    • Participate in industry working groups
    • Publish best practices guide

11.3 Continuous Monitoring

Ongoing Activities:

  • Monthly procurement team review of new supplier risks
  • Quarterly executive team review of KPIs
  • Annual Board review and approval of statement
  • Regular policy updates to reflect emerging risks
  • Engagement with external experts and stakeholders

12. APPROVAL AND SIGN-OFF

This statement has been approved by the Board of Directors of Cognitiva Systems Inc.

Signed:

On behalf of the Board of Directors
Cognitiva Systems Inc.
Date: 15 April 2026

13. CONTACT INFORMATION

Questions or Concerns:

Modern Slavery concerns can be reported to:

Email: ethics@cognitiva.systems
Phone: +1 302-217-6601

External Reporting: UK Modern Slavery Helpline: 08000 121 700
US National Human Trafficking Hotline: 1-888-373-7888

14. STATEMENT PUBLICATION

Published: 15 April 2026
Financial Year Covered: April 2025 – April 2026
Next Statement Due: October 2026

Availability:

Previous Statements:

  • This is the first published statement (2026).

END OF MODERN SLAVERY ACT STATEMENT

Version: 1.0
Approved by: Board of Directors, 15 April 2026
Next Review: April 2027

APPENDIX A: DEFINITIONS

Modern Slavery: An umbrella term encompassing slavery, servitude, forced and compulsory labor, and human trafficking.

Forced Labor: Work or service extracted from any person under menace of penalty and for which the person has not offered themselves voluntarily.

Human Trafficking: Recruitment, transportation, transfer, harboring, or receipt of persons by means of threat, force, coercion, abduction, fraud, deception, abuse of power, or vulnerability for exploitation.

Child Labor: Work that deprives children of their childhood, potential, and dignity, and is harmful to physical and mental development.

Debt Bondage: Forcing a person to work to pay off a debt, without the freedom to leave or ability to pay off the debt.

Supplier: Any entity providing goods or services to Cognitiva, including direct suppliers and sub-suppliers.

Due Diligence: Reasonable steps to identify, prevent, mitigate, and account for modern slavery risks in operations and supply chain.

APPENDIX B: RED FLAGS

Indicators of Modern Slavery:

Employee/Worker Red Flags:

  • Restricted freedom of movement
  • Retention of identity documents
  • Excessive work hours with little or no rest
  • Poor living conditions
  • Fear or anxiety when speaking to authorities
  • Inability to leave employment
  • Debt to employer or recruiter
  • Unpaid or below minimum wage
  • Physical or psychological abuse

Supplier Red Flags:

  • Refuses audits or transparency
  • Located in high-risk jurisdiction without mitigation
  • Uses labor brokers or agencies extensively
  • Frequent worker turnover
  • Workers lack contracts or documentation
  • Site security prevents worker departure
  • Workers living on-site in poor conditions
  • Discrepancies between worker and management accounts

Recruitment Red Flags:

  • Candidate charged recruitment fees
  • Passport or documents held by recruiter
  • Misleading job descriptions
  • Unrealistic job promises
  • Inability to refuse job offer
  • Debt to recruiter
  • Accompanied by controller to interview

APPENDIX C: USEFUL RESOURCES

UK Resources:

US Resources:

International Resources:

Industry Resources:

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