# Modern Slavery and Human Trafficking Statement

Datafalk Inc. · Voluntary statement as at the date of publication · Approved by resolution of the Board of Directors of Datafalk Inc. · Published: 28 October 2026

## 1. Introduction

This statement is made voluntarily by Datafalk Inc. on behalf of itself and of Parallax 84 SAS (together, "Datafalk"), in the spirit of section 54 of the United Kingdom Modern Slavery Act 2015 and of the California Transparency in Supply Chains Act, neither of which applies to Datafalk at the date of this statement given its size and activities. We publish it because transparency on forced labour and human trafficking is the subject of our business and because our customers expect it of their suppliers. It describes the position of Datafalk as at the date of publication, since the incorporation of Datafalk Inc. on 21 July 2026, and the steps we are taking to ensure that slavery and human trafficking do not take place in our business or supply chains. A statement covering a completed financial year will be published annually from the financial year ending 31 December 2027.

## 2. Our organisation and business

Datafalk Inc. is a corporation organised under the laws of the State of Delaware, United States of America. It owns the Datafalk supply chain risk intelligence platform, which maps multi-tier supplier networks, monitors disruptions, supports the assessment of current and potential suppliers and helps customers understand and anticipate how their supply chains may fail. The platform is operated from France by Parallax 84 SAS, which also distributes the Services in Europe, and is hosted on infrastructure in Germany. Datafalk operates with a small team of founders, engineers and analysts based in France and the United States, and engages independent contractors for specific projects. Datafalk does not manufacture, transport or sell physical goods.

## 3. Our supply chain

Datafalk's own supply chain consists of cloud hosting and infrastructure providers in the European Union, software, data and artificial intelligence providers, professional services (legal, accounting, corporate services, recruitment), office and equipment suppliers and independent technology contractors. These suppliers are located predominantly in the European Union, the United Kingdom and the United States, in sectors where the risk of forced labour is generally assessed as low. The highest residual risk lies in the extended supply chains of our hardware and equipment suppliers, which we do not control directly.

## 4. Our policies

Datafalk's Code of Business Conduct and Ethics prohibits any form of forced, bonded or compulsory labour, child labour and human trafficking in our operations and requires our suppliers to apply the same standard. Our Anti-Bribery and Anti-Corruption Policy addresses the corruption that frequently accompanies labour exploitation. Our recruitment practices verify the identity, age and right to work of every person we employ; we never charge recruitment fees to workers and we never retain identity documents. These policies are adopted by the Board of Directors of Datafalk Inc. and by the legal representative of Parallax 84 SAS at the same time as this statement.

## 5. Due diligence

Datafalk screens its suppliers and contractors against sanctions and forced labour lists and adverse media before engaging them, using the same monitoring tools that it provides to its customers, and includes in its supplier contracts compliance with applicable labour and anti-slavery laws, a right to request information and a right of termination for breach. As at the date of this statement, this screening has been applied to all suppliers and contractors engaged by Datafalk Inc. and Parallax 84 SAS, and has identified no finding. We have identified no instance of modern slavery in our supply chain; we do not regard the absence of findings as proof of its absence, and we will repeat the screening at each renewal and before each new engagement.

## 6. Our contribution through our Services

Datafalk's platform is used by its customers to identify forced labour risk in their own multi-tier supply chains, through the mapping of sub-tier suppliers that are otherwise invisible to the buyer, the detection of suppliers located in high-risk regions, the screening of adverse media and sanctions lists, the assessment of current and potential suppliers, and the analysis of how a supply chain may fail. We consider this contribution to be our most significant lever against modern slavery, while recalling that our products provide research information and do not certify that a supply chain is free of exploitation.

## 7. Training and awareness

Datafalk's team works daily on supply chain due diligence legislation, including the European Corporate Sustainability Due Diligence Directive, the European Forced Labour Regulation and the United States Uyghur Forced Labor Prevention Act, in the course of its work for customers. Every member of the team receives the Code of Business Conduct and Ethics and this statement on joining and acknowledges them. A specific training session on modern slavery indicators in our own supply chain will be held before the next statement.

## 8. Measuring effectiveness

We will assess the effectiveness of these steps by the proportion of suppliers and contractors screened before engagement, the proportion of existing suppliers re-screened when due, the number of concerns raised through our reporting channel (ethics@datafalk.com) and the time taken to address them. We will report on these indicators in the next statement.

## 9. Approval

This statement was approved by the Board of Directors of Datafalk Inc. by unanimous written consent and is signed on its behalf by Louis Ramard, Director and Chief Executive Officer. It will be reviewed and updated annually.
