Modern Slavery Statement

Last updated: [TBD] · This is a working draft pending legal review.

1. Introduction and purpose

Coded B.V. ("Coded", "we", "us", "our") is committed to operating responsibly and to acting with integrity in all of its business dealings and relationships. Modern slavery — including forced labour, bonded labour, child labour, servitude, and human trafficking — is a serious violation of fundamental human rights. We have zero tolerance for it, in any part of our own operations or in any of the supply chains and business relationships connected to our platform.

This statement describes the steps Coded has taken, and intends to take, to understand and address the risk of modern slavery and human trafficking in our operations and supply chain. It is written to reflect the expectations of the UK Modern Slavery Act 2015 (section 54) as a recognised international benchmark for transparency, and to serve as a single, globally applicable statement of our position. Coded is an international company serving merchants worldwide; this statement is not limited to any single market.

This statement is published voluntarily as part of our commitment to transparency. Where it is also a legal requirement in a jurisdiction in which we operate, it is intended to satisfy that requirement.

2. About Coded

Coded B.V. is a private limited company (besloten vennootschap) registered in the Netherlands. Coded Holding B.V. is its parent company.

• Registered office: De Taling 15, 2761 SL Zevenhuizen, The Netherlands
• Chamber of Commerce (KVK) number: 42027097
• VAT number: NL869368795B01

Coded operates a commerce platform on which a merchant can run one or more branded online shops, drawing on a curated product catalog, with built-in payments and built-in fulfilment. The merchant's shops, sites, and other things they create are referred to with the umbrella term "projects", and a merchant's account is referred to in our product as an "Organization". We charge a 0% platform fee on a merchant's payment transactions; merchants pay only the pass-through payment-processing cost charged by our payment providers. Subscription fees may apply separately to publishing a project.

Our platform infrastructure and customer data are hosted within the European Union (Frankfurt, Germany), which supports a strong data-protection and rule-of-law baseline across our operations.

3. Our operations and our people

The majority of our direct workforce consists of software, product, design, and operations professionals, engaged either as employees of Coded B.V. or as contracted personnel through established development partners. These roles are skilled and salaried, and we consider the risk of modern slavery within our own direct workforce to be low.

We nonetheless apply the same standards across our direct and contracted workforce:

• All workers are entitled to fair, lawfully compliant pay and working conditions.
• We do not tolerate the withholding of identity documents, recruitment fees charged to workers, debt bondage, or any restriction on a worker's freedom to leave their employment.
• Where we engage third-party staffing or development partners, we expect those partners to apply equivalent labour standards to the personnel they assign to Coded.

4. Our supply chain

For the purpose of assessing modern slavery risk, our supply chain has two principal components.

4.1 Corporate and technology supply chain

This covers the goods and services Coded itself buys to operate as a business: cloud hosting and infrastructure, payment-processing services, software tooling and subscriptions, professional services, and office-related goods and services. These suppliers are predominantly established technology and professional-services providers operating in jurisdictions with mature labour protections. We consider the inherent modern slavery risk in this component to be relatively low, while recognising that risk is never zero.

4.2 Platform-related supply chain (product sourcing and fulfilment)

Coded provides merchants with a curated product catalog and built-in fulfilment. The physical products in this catalog, and the warehousing, handling, packing, and shipping activities involved in fulfilling orders, are sourced and performed through third-party suppliers and logistics partners. Because product manufacturing and fulfilment can involve lower-skilled labour and complex, multi-tier, cross-border supplier networks, we recognise this as the area of our supply chain carrying the highest inherent modern slavery risk, and we focus our due diligence accordingly.

We are transparent that we do not directly employ the workers in these manufacturing and fulfilment operations and do not have complete visibility into every tier of every supplier. Our approach is therefore one of risk-based due diligence, contractual standards, and continuous improvement rather than a claim of perfect oversight.

5. Our policies

We maintain — or are in the process of formalising — the following policies that bear on modern slavery and human trafficking:

• Code of Conduct — sets the ethical standards expected of everyone working for or on behalf of Coded, including respect for human rights.
• Supplier Code of Conduct — sets out the labour, human-rights, and ethical standards we require of suppliers and partners, including an explicit prohibition on forced labour, child labour, and human trafficking, and an expectation that suppliers cascade equivalent standards to their own suppliers.
• Anti-Slavery and Human Trafficking position — articulated in this statement: zero tolerance, risk-based due diligence, and a commitment to remediation where harm is identified.
• Whistleblowing / Speak-Up policy — provides a confidential channel for raising concerns, including concerns about modern slavery, without fear of retaliation.
• Recruitment and onboarding standards — designed to confirm that workers are recruited lawfully, are eligible to work, and are paid directly and fairly.

6. Due diligence and risk assessment

Our due-diligence approach is risk-based and proportionate to where we believe the greatest risk lies — principally the platform-related product sourcing and fulfilment supply chain.

Our intended due-diligence measures include:

• Supplier risk screening — assessing suppliers and fulfilment partners by sector, product category, and country-of-operation risk indicators, prioritising higher-risk relationships for closer scrutiny.
• Contractual safeguards — requiring suppliers and partners to commit, by contract or by acceptance of our Supplier Code of Conduct, to prohibiting modern slavery, complying with applicable labour laws, and permitting reasonable verification.
• Onboarding checks — gathering relevant information on a supplier's labour practices, sub-contracting, and sourcing before onboarding higher-risk suppliers.
• Ongoing monitoring — periodic review of higher-risk relationships, supported by third-party risk data where available.
• Escalation and remediation pathway — a defined route to investigate credible concerns, suspend or terminate non-compliant suppliers, and prioritise the protection and remediation of affected workers over commercial convenience.
• Grievance and reporting channels — the Speak-Up channel referenced above, available to workers, merchants, and the public.

As a first-pass position, we are transparent that several of these measures are being established and matured rather than fully operational. We will report on progress in future versions of this statement.

7. Risk areas we focus on

Based on our current understanding, the modern slavery risks most relevant to Coded are:

• Forced or child labour in the manufacture of products in the curated catalog, particularly in lower-cost, multi-tier manufacturing regions.
• Exploitative labour conditions in warehousing, handling, and last-mile logistics within the fulfilment supply chain.
• Labour exploitation among outsourced or sub-contracted personnel engaged indirectly to support Coded's own operations.

We do not consider our core software, payments, and hosting relationships to be high-risk, but we keep them within scope of review.

8. Effectiveness and measurement

We are establishing key performance indicators to measure the effectiveness of our approach over time. Indicators under consideration include:

• the proportion of higher-risk suppliers and fulfilment partners that have accepted our Supplier Code of Conduct;
• the number of supplier risk assessments completed;
• the number of concerns raised through grievance channels and how they were resolved;
• the proportion of relevant staff who have completed modern slavery awareness training.

We will report on these indicators as the underlying processes mature. Where, in a given period, no action of a particular kind has been taken, we will say so plainly rather than imply otherwise.

9. Training and awareness

We aim to provide relevant personnel — particularly those involved in supplier selection, catalog curation, fulfilment operations, and procurement — with awareness training on identifying and responding to modern slavery risk. Awareness of our Speak-Up channel is promoted across the workforce so that concerns can be raised early and safely.

10. Continuous improvement

We regard tackling modern slavery as an ongoing programme, not a one-time exercise. We will review and update this statement at least annually, and sooner if there is a material change to our operations or supply chain, refining our policies, due diligence, and reporting as our understanding and our processes mature.

11. Governance and approval

This statement is made on behalf of Coded B.V. It is intended to be reviewed and approved by the board of directors of Coded B.V. (and, where appropriate, of Coded Holding B.V.) and signed by a director prior to publication.

• Approved by: [Name, Director] <!-- confirm signatory -->
• On behalf of: Coded B.V.
• Date: 11 June 2026
• Period covered: [financial year — confirm] <!-- confirm reporting period -->

12. Governing law

This statement, and any dispute or claim arising out of or in connection with it, is governed by the laws of the Netherlands, and the courts of Amsterdam shall have jurisdiction. This does not override any mandatory provision of the law of a user's, worker's, or supplier's own jurisdiction that applies regardless of this choice, and nothing in this statement limits rights or obligations arising under applicable local law.

Contact

Questions, concerns, or reports relating to modern slavery and human trafficking can be raised with us at:

• Email: legal@coded.eu
• Postal: Coded B.V., De Taling 15, 2761 SL Zevenhuizen, The Netherlands

Confidential concerns may also be raised through our Speak-Up channel. We will not tolerate retaliation against anyone who raises a concern in good faith.