Modern Slavery Statement

Last updated: July 9, 2026

This is a voluntary statement, prepared with reference to Section 54 of the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018. TerminalStreet LLC ("TerminalStreet," "we," "us," or "our") is not currently subject to the mandatory reporting thresholds of those Acts. We publish this statement because we consider the commitments in it important. It describes our approach for the financial year ending December 31, 2024.

1. Organizational Structure and Business Activities

TerminalStreet LLC is a technology company headquartered in Wyoming, USA, specializing in innovative solutions including artificial intelligence, blockchain technology, and financial technology services. Our operations include software development, consulting services, training, and technology implementation.

We operate primarily in North America, with growing service provision in Europe and the Asia-Pacific region. While our business model is predominantly based on intellectual services and digital products, we recognize that modern slavery risks can exist in any supply chain or business operation.

2. Our Supply Chains

Our supply chains primarily consist of:

• Technology infrastructure providers (cloud computing, data centers, hardware)
• Software and technology service providers
• Professional services (legal, accounting, consulting)
• Office supplies and equipment
• Marketing and promotional products
• Travel-related services
• Contracted development and project resources

We recognize that even in a technology-focused supply chain, modern slavery risks may exist, particularly in hardware manufacturing, data center operations, and certain geographies with higher risk profiles.

3. Our Policies on Modern Slavery

Our commitment to combating modern slavery is reflected in several key policies and documents:

• Code of Ethics and Business Conduct: Sets out our expectations for ethical behavior throughout our operations
• Supplier Code of Conduct: Explicitly prohibits forced labor, child labor, and human trafficking in our supply chains
• Whistleblowing Policy: Provides channels for reporting concerns about unethical practices, including modern slavery
• Recruitment Policy: Includes safeguards against modern slavery in our hiring practices
• ESG Statement: Outlines our broader commitment to social responsibility, including human rights

These policies are reviewed regularly and updated as necessary to ensure they remain effective and aligned with evolving best practices and legal requirements.

4. Risk Assessment and Due Diligence

4.1 Risk Assessment Approach

We take a risk-based approach to assessing modern slavery risks in our operations and supply chains, considering factors such as:

• Geographic risk (based on country-level indicators of modern slavery prevalence)
• Industry sector risk (with particular attention to hardware manufacturing and facilities services)
• Business model risks (including use of contracted or temporary labor)
• Product/service category risks (identifying higher-risk categories in our procurement)
• Supply chain visibility (assessing how far we can trace our supply chains)

4.2 Due Diligence Processes

Our due diligence processes for identifying and mitigating modern slavery risks include:

• Supplier Screening: Assessment of new suppliers against risk criteria before onboarding
• Contractual Provisions: Inclusion of modern slavery compliance clauses in supplier agreements
• Self-Assessment Questionnaires: Requiring higher-risk suppliers to complete detailed questionnaires on their labor practices
• Documentation Verification: Reviewing relevant documentation from suppliers, including their own modern slavery statements
• Ongoing Monitoring: Regular review of supplier compliance and changes in risk profiles

In 2024, we enhanced our due diligence process by implementing a digital supplier management system that allows us to track compliance more efficiently and maintain better visibility into our supply chain.

5. Risk Management and Actions Taken

Based on our risk assessment and due diligence processes, we have taken the following actions to manage and mitigate modern slavery risks:

• Supply Chain Mapping: We have mapped our tier 1 suppliers and begun extending visibility to tier 2 suppliers in higher-risk categories
• Risk Mitigation Plans: We have developed specific risk mitigation plans for suppliers identified as higher risk
• Procurement Practices: We have updated our procurement policies to incorporate modern slavery considerations into sourcing decisions
• Supplier Engagement: We actively engage with key suppliers to promote awareness and improvement in labor practices
• Collaboration: We participate in industry initiatives addressing modern slavery in technology supply chains

In the reporting period, we identified several areas for improvement in our hardware procurement and contracted service providers. We have taken targeted actions to address these specific risks, including implementing more detailed screening for these categories.

6. Training and Awareness

We recognize that effective action against modern slavery requires awareness and understanding at all levels of our organization. Our approach to training and awareness includes:

• Employee Training: All employees receive information about modern slavery as part of their onboarding
• Specialized Training: Enhanced training for teams involved in procurement, contracting, and supplier management
• Refresher Training: Annual refresher training on ethical business practices, including modern slavery awareness
• Resource Library: Maintaining accessible resources on identifying and reporting modern slavery concerns
• Leadership Engagement: Regular updates to leadership on modern slavery risks and mitigation efforts

In 2024, we enhanced our training program by developing industry-specific modules that highlight modern slavery risks in technology supply chains, with particular focus on hardware manufacturing and data center operations.

7. Effectiveness and Performance Indicators

To assess the effectiveness of our actions to prevent modern slavery, we monitor the following key performance indicators:

• Training Completion: Percentage of relevant staff who have completed modern slavery awareness training
• Supplier Assessment: Percentage of suppliers that have been screened for modern slavery risks
• Due Diligence Coverage: Percentage of high-risk suppliers that have undergone enhanced due diligence
• Contractual Compliance: Percentage of supplier contracts that include modern slavery provisions
• Reported Concerns: Number and nature of concerns raised through our reporting mechanisms
• Remediation Actions: Number and effectiveness of remediation actions taken to address identified risks

We review these indicators regularly to identify trends and areas for improvement. In 2024, we achieved 100% training completion for procurement staff, increased our supplier screening coverage to 95% of all new suppliers, and implemented modern slavery provisions in all new supplier contracts.

8. Specific Considerations for Technology Operations

8.1 Hardware Supply Chain

While we primarily provide software and services, we recognize specific risks in the hardware we procure:

• We prioritize hardware suppliers with robust human rights programs and transparency
• We seek to understand the sourcing of components, particularly those containing minerals from conflict-affected regions
• We review independent audits and certifications related to labor practices in manufacturing facilities

8.2 Data Center Operations

For cloud infrastructure and data centers:

• We assess labor practices in the construction and maintenance of data center facilities
• We review the modern slavery statements and labor policies of our major cloud service providers
• We include questions about subcontracted labor in our due diligence for infrastructure services

8.3 Software Development

In our core software development operations:

• We ensure fair labor practices for all employees and contractors engaged in development work
• We maintain transparency in our global development team structure and working conditions
• We apply consistent labor standards regardless of location or employment model

9. Reporting Mechanisms

We maintain several channels for reporting concerns about modern slavery or other ethical issues:

• Ethics Hotline: A confidential hotline available to employees, contractors, and external stakeholders
• Online Reporting Tool: A web-based system for submitting concerns, with options for anonymous reporting
• Direct Reporting: The ability to report concerns directly to management or our legal team
• Supplier Channel: A dedicated channel for suppliers to raise concerns about labor practices in our supply chain

All reports are taken seriously, investigated thoroughly, and addressed appropriately, with a strict non-retaliation policy protecting those who report concerns in good faith.

10. Future Commitments

Building on our existing efforts, we have set the following goals for the coming year:

• Expand our supply chain mapping to include all tier 2 suppliers in high-risk categories
• Enhance our supplier audit program to include more detailed assessment of labor practices
• Develop additional training modules focused on specific high-risk areas in our operations
• Increase collaboration with other technology companies to address shared challenges in combating modern slavery
• Implement a supplier recognition program for best practices in preventing modern slavery
• Integrate modern slavery considerations more deeply into our procurement scoring and decision-making

We recognize that addressing modern slavery requires ongoing vigilance and continuous improvement, and we remain committed to strengthening our approach over time.

11. Governance and Approval

Responsibility for our modern slavery prevention efforts is overseen by the management of TerminalStreet LLC, with day-to-day implementation managed by our legal, procurement, and human resources functions.

This statement has been approved by the Managing Member of TerminalStreet LLC and will be reviewed and updated annually.

For questions or concerns related to this statement or our modern slavery prevention efforts, please contact:

[email protected]