Modern Slavery Statement

Our Organisation and Business

Smart City Operating System Limited (trading as scOS) is a company registered in England and Wales (company number 13569571), with its registered office at 71 Manor Road, Luton, LU1 4EE, United Kingdom, and its trading and correspondence address at 4th Floor, Silverstream House, 45 Fitzroy Street, London, W1T 6EB. Our business is based in and operated from the United Kingdom, and we serve customers in the United Kingdom.

We design and operate an AI-assisted home and property security service, delivered to customers on a subscription basis. Our service combines connected security hardware, installed at the customer’s premises, with cloud-based software that provides monitoring, verification and home-automation features.

We are a director-led UK business. Our activities are carried out by our director together with our team of specialist contractors and service providers. Because our workforce is UK-based and made up of skilled professionals, we assess the risk of modern slavery within our own operations to be low. We recognise, however, that the greater inherent risk sits within our extended supply chain, as described below.

Our Supply Chains

Our supply chain supports the design, manufacture, assembly, fulfilment and cloud delivery of our product. Its principal categories are:

• Electronic hardware and related components— procured predominantly through UK-based suppliers.
• Hardware assembly and provisioning— performed by UK-based manufacturing and assembly partners.
• Logistics and fulfilment— warehousing, dispatch and courier services provided by UK-based partners.
• Cloud, connectivity and payments— cloud computing, networking and payment-processing services provided by established technology and financial-services providers.
• Professional services— legal, accountancy, insurance and similar advisers.

While our direct suppliers are predominantly UK-based and subject to UK law, we recognise that the electronic components we purchase have extended upstream supply chains — including semiconductor fabrication, raw-material extraction and overseas electronics manufacturing — that can reach into higher-risk jurisdictions. We therefore consider the extended electronics supply chain to be the area of our business with the greatest inherent modern-slavery risk, and we focus our due diligence accordingly.

Our Policies

We operate on the following principles, and we are formalising them into written policies as our team grows:

• Zero tolerance of slavery, servitude, forced or compulsory labour and human trafficking in our business and supply chain.
• Supplier expectations— we are introducing a supplier code of conduct requiring suppliers to comply with the Modern Slavery Act 2015 and to prohibit forced, bonded and child labour, and we expect suppliers to hold their own supply chains to equivalent standards.
• Fair and lawful engagement— we engage our contractors and service providers on lawful, arm’s-length commercial terms and do not use unpaid, forced or coerced labour. As we take on employees and workers, we will carry out right-to-work checks and pay at or above the applicable statutory minimums.
• Speak-up route— anyone working in, or with, our business can raise concerns about modern slavery through our contact page, and we are committed to investigating and acting on any concern raised.

We are honest that some of these controls are still being formalised as our business grows. This statement records both the steps already in place and the further steps we are committed to putting in place as we scale.

Due Diligence and Risk Management

We take the following steps, proportionate to our size and stage, to identify and manage modern-slavery risk:

• We source hardware primarily through reputable UK-based suppliers and manufacturers who are themselves subject to UK law and, in many cases, publish their own modern-slavery statements.
• As we onboard contract manufacturers and other material suppliers, we will include modern-slavery and human-trafficking obligations in our supplier contracts, request suppliers’ own modern-slavery policies or statements, and give preference to suppliers who can demonstrate responsible labour practices.
• We favour a short, UK-based supply and assembly chain wherever commercially practical, which reduces the number of intermediaries and improves visibility and traceability.
• We provide a route for concerns to be raised, and we will investigate and act on any credible indication of modern slavery in our operations or supply chain.

Based on this assessment, we regard the risk of modern slavery within our own UK operations as low, with the principal residual risk sitting in the extended electronics supply chain. We currently manage that residual risk primarily through careful supplier selection, and we will strengthen contractual controls as our supplier relationships mature.

Measuring Effectiveness

As a small company we do not yet operate a formal set of modern-slavery performance indicators. As our business and team grow, we intend to measure the effectiveness of our approach by tracking, for example:

• the proportion of our material suppliers who have accepted our supplier code of conduct or provided their own modern-slavery statement;
• the number of modern-slavery concerns raised and how they were resolved; and
• the completion of modern-slavery awareness briefings by relevant members of our team.

We will report on our progress in future versions of this statement.

Training and Awareness

The company’s director maintains awareness of modern-slavery risks and how they may present in our sector and supply chain. As we build our team, we will provide modern-slavery awareness training to relevant staff — particularly those involved in procurement, supplier management and operations — so that they can identify and escalate concerns.

Approval

This statement is made in relation to section 54(1) of the Modern Slavery Act 2015. It describes the position of Smart City Operating System Limited as at the date below and will be reviewed and updated at least annually.

This statement was approved by the director of Smart City Operating System Limited on 6 July 2026.