Modern Slavery Statement

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Introduction

Modern slavery is a serious crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking. CLS UK recognises that modern slavery is a global issue that can occur across sectors and supply chains.

COLLECTE LOCALISATION SATELLITES (CLS) UK LIMITED (“CLS UK”) has a zero-tolerance approach to modern slavery and is fully committed to acting ethically and with integrity in all business dealings. We are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place within our operations or supply chains.

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps CLS UK has taken during the financial year ending 31 December 2024 to prevent modern slavery and human trafficking in our business and supply chains.

Our Business and Supply Chains

CLS UK provides maritime tracking via satellite, search and rescue services, and fisheries tracking services.

Registered office:
CLS UK
3 Park Mews
15 Park Lane
Hornchurch
Essex
RM11 1BB

CLS UK forms part of the wider CLS Group, which operates globally.

Our supply chain primarily includes:

  • Technology and satellite service providers

  • IT and software providers

  • Professional services suppliers

  • Office and facilities service providers

We seek to build long-term relationships with suppliers based on trust, transparency, and compliance with applicable laws and ethical standards.

Risk Assessment

During the reporting period, CLS UK conducted a risk-based assessment of its supply chain, taking into account:

  • Country risk profiles (including reference to the Global Slavery Index)

  • The nature of services provided

  • The potential presence of vulnerable labour groups

  • Publicly available information, including media and NGO reports

Based on our assessment, we consider the overall risk within our direct operations to be low; however, we remain vigilant regarding potential indirect supply chain risks.

Policies and Governance

CLS UK maintains the following policies to mitigate the risk of modern slavery:

  • Whistleblowing Policy – Enables employees, suppliers, and stakeholders to report concerns confidentially and without fear of retaliation.

  • Code of Conduct – Sets out expected standards of integrity, ethical behaviour, and compliance.

  • Purchasing Code and Supplier Terms – Explicitly prohibit forced labour, human trafficking, and exploitative employment practices.

These policies are reviewed periodically to ensure they remain effective and aligned with legal obligations.

Supplier Due Diligence

CLS UK conducts proportionate due diligence on new suppliers during onboarding and periodically reviews existing suppliers.

Our due diligence may include:

  • Risk-based supplier screening

  • Review of labour practices

  • Contractual commitments regarding compliance with modern slavery legislation

  • Audit rights where appropriate

  • Remedial action plans where standards are not met

We require suppliers to confirm that:

  • They do not use forced, bonded, or compulsory labour

  • Employment is freely chosen

  • Employees are free to leave employment with reasonable notice

  • Wages are paid in full and on time

  • Identity documents are not withheld

To date, CLS UK has not identified any substantiated instances of modern slavery within its operations or supply chain during the reporting period.

Effectiveness and Monitoring

We assess the effectiveness of our anti-slavery measures through:

  • Ongoing supplier reviews

  • Monitoring whistleblowing reports

  • Risk assessment updates

  • Contractual compliance checks

No incidents of modern slavery have been reported.

Training

Relevant employees involved in procurement and supplier management are made aware of modern slavery risks and our internal reporting procedures. We will continue to evaluate training requirements to ensure appropriate awareness across the organisation.

Approval

This statement has been approved by the Board of Directors of COLLECTE LOCALISATION SATELLITES (CLS) UK LIMITED and is signed on its behalf by:

Name: Tracy Nichols
Title: Director
Date: 20/02/2026