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:

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:

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:

2. SUPPLY CHAINS

2.1 Supply Chain Overview

Cognitiva's supply chain consists primarily of:

Digital Services:

Professional Services:

Hardware (Limited):

2.2 Geographic Supply Chain

Primary Supplier Locations:

Risk Assessment:

2.3 Supplier Categories

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

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

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

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

3. POLICIES AND PROCEDURES

3.1 Code of Conduct

Employee Code of Conduct:

All employees and contractors must:

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:

Contractor Engagement:

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:

New Supplier Onboarding:

3.4 Whistleblowing Policy

Reporting Mechanism:

Employees, contractors, and suppliers can report concerns via:

Protection:

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:

Sector Risk:

Tier Risk:

Current Risk Profile:
Overall risk: LOW

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:

4.3 Contractor Due Diligence

Independent Contractors:

For each contractor engagement:

Freelance Platforms:

5. TRAINING AND AWARENESS

5.1 Employee Training

Modern Slavery Awareness Training:

Target Audience:

Training Content:

Delivery Method:

Completion Tracking:

Current Status:

5.2 Specialized Training

Procurement Team:

HR/Recruitment:

Leadership:

6. PERFORMANCE INDICATORS

6.1 Key Performance Indicators (KPIs)

We measure effectiveness through:

Supplier Compliance:

Training:

Reporting:

Risk Assessment:

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:

Level 2 - Moderate Non-Compliance:

Level 3 - Severe Non-Compliance:

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:

8. COLLABORATION AND ENGAGEMENT

8.1 Industry Collaboration

Partnerships:

Knowledge Sharing:

8.2 Stakeholder Engagement

Employees:

Suppliers:

Customers:

Civil Society:

8.3 Transparency

Public Disclosure:

Reporting:

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:

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:

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:

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:

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:

April 2025 – April 2026 Board Actions:

10.2 Executive Responsibility

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

Responsibilities:

10.3 Cross-Functional Team

Modern Slavery Working Group:

Members:

Activities:

10.4 External Assurance

Independent Review:

Certifications:

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:

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:

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:

Supplier Red Flags:

Recruitment Red Flags:

APPENDIX C: USEFUL RESOURCES

UK Resources:

US Resources:

International Resources:

Industry Resources:

← All legal documents
Modern Slavery Statement — Cognitiva Systems | Cognitiva