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Modern Slavery & Human Trafficking Statement

Robelium Ltd

(Section 54, UK Modern Slavery Act 2015)

Last Update: 1 March 2026

1. Statement of Commitment

Robelium Ltd is committed to preventing modern slavery, forced labour, servitude, human trafficking, and exploitation within its operations, workforce, partner ecosystem, and supply chain.

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015.

Although Robelium may not currently meet the statutory turnover threshold for mandatory publication, this statement is issued voluntarily as part of the company's governance, risk management, and long-term infrastructure framework.

Robelium recognises that responsibility extends beyond direct employment relationships and includes oversight of independent partners, contractors, and commercial relationships.


2. Organisational Scope

This statement applies to:

• Robelium Ltd and its directors

• Employees and internal workforce

• Independent contractors engaged by the company

• Independent partner recovery operators

• Fleet clients using the platform

• Enterprise clients and commercial integrators

• Third-party technology providers

• Any future subsidiaries or international operations

Robelium operates as a real-time coordination and governance platform and does not directly employ recovery operators.

However, the company acknowledges that governance responsibilities extend across the broader operational ecosystem.


3. Internal Workforce & Contractors

Robelium's internal workforce operates within the United Kingdom.

The company commits to:

• Compliance with UK employment law

• Lawful right-to-work verification

• Fair and transparent remuneration

• Written contractual agreements

• Protection against coercion or forced labour

• Zero tolerance for exploitative employment practices

Any contractors engaged by Robelium are subject to written agreements and are expected to comply with applicable labour regulations.


4. Partner Ecosystem (Recovery Operators)

Recovery operators using the Robelium platform are independent businesses.

Robelium does not directly control partner employment practices; however, the company implements structured governance mechanisms to mitigate risk.

These include:

• Partner onboarding verification

• Structured activation controls

• Compliance scoring framework

• Behavioural monitoring

• Suspension and removal mechanisms

• Data-driven oversight via Service Coordination Centre

Robelium expects all partners to:

• Comply with UK labour legislation

• Ensure lawful employment practices within their own workforce

• Avoid subcontracting arrangements that violate labour laws

• Avoid exploitative practices

Where credible concerns arise, Robelium reserves the right to suspend platform access pending review.


5. Fleet & Enterprise Clients

Robelium may provide services to fleet operators, commercial clients, and enterprise entities.

The company expects commercial clients to operate in compliance with applicable labour standards.

Where appropriate, Robelium may:

• Review contractual obligations

• Require compliance representations

• Incorporate ethical conduct clauses

As Robelium expands into fleet and insurer integrations, governance safeguards will be updated proportionately.


6. Supply Chain & Third-Party Providers

Robelium engages third-party service providers including:

• Cloud infrastructure providers

• Payment processors

• Mapping and routing services

• Legal and professional advisors

Major technology providers typically maintain their own Modern Slavery Statements.

Robelium expects suppliers to:

• Comply with UK and applicable international labour laws

• Maintain their own anti-slavery policies

• Avoid exploitative labour practices

Risk assessments may be updated as supply chain complexity increases.


7. Risk Areas Identified

Potential areas of exposure include:

• Indirect subcontracting within partner organisations

• Cross-border technology supply chains

• Future international expansion

• Fleet integrations involving multi-layered service providers

Robelium assesses its direct operational risk as low but acknowledges that indirect risks require continued monitoring.


8. Due Diligence & Monitoring

Robelium applies proportionate due diligence measures, including:

• Identity verification of partners

• Behavioural monitoring via compliance scoring

• Structured complaint handling

• Audit logging of operational activity

• Escalation procedures for credible concerns

As scale increases, the company intends to formalise enhanced due diligence processes appropriate to operational growth.


9. Reporting & Whistleblowing

Concerns relating to forced labour, human trafficking, or exploitative practices may be reported to:

[email protected]

Reports are reviewed internally and escalated where necessary.

Retaliation against individuals raising concerns in good faith will not be tolerated.


10. Governance & Oversight

Oversight responsibility rests with the Director(s) of Robelium Ltd.

Modern slavery risk is considered within the broader governance and risk management framework of the company.

As Robelium scales, governance mechanisms will evolve accordingly.


11. Continuous Improvement

Robelium commits to:

• Annual review of this statement

• Updating policies in line with operational growth

• Monitoring regulatory developments

• Enhancing oversight as ecosystem complexity increases

The company recognises that governance must scale with operational footprint.


12. Approval

This statement has been approved by the Director of Robelium Ltd.

Signed on behalf of Robelium Ltd

Director

Robelium Ltd