Modern Slavery Act Statement

Effective date: July 07, 2025

Cloud in India Limited (“Cloud in India”, “we”, “us”, “our”) is committed to preventing modern slavery and human trafficking in our business and supply chains. This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 for the financial year 1 April 2024 – 31 March 2025 and describes our governance, policies, risk assessment, due diligence, training, and performance indicators.

1) Our Organisation & Structure

Cloud in India is a technology consultancy specialising in Salesforce implementation, data & AI, integrations, analytics, and managed services. We operate with UK leadership and offshore delivery capabilities. Our supply chain primarily comprises professional services, software (SaaS), cloud hosting, recruitment/contracting, office facilities, and equipment.

2) Our Policy Framework

• Modern Slavery & Human Trafficking Policy — zero tolerance across our operations and supply chain.
• Supplier Code of Conduct — mandates compliance with labour laws, safe working conditions, fair pay, and freedom from coercion.
• Whistleblowing Policy — confidential channels for employees, contractors, and suppliers; non-retaliation guaranteed.
• Recruitment & Right-to-Work Policy — robust identity and right-to-work checks; no recruitment fees borne by workers.
• Equality, Diversity & Inclusion Policy — fosters dignity at work and prohibits discrimination and harassment.
• Third-Party Risk Management — integrates human rights criteria into onboarding and ongoing supplier reviews.

3) Risk Assessment

We periodically assess modern slavery risks using a risk-based matrix considering sector, geography, spend category, labour intensity, subcontracting layers, and transparency. Higher inherent risk may exist in:

• Facilities & Office Services (e.g., cleaning, catering, maintenance)
• Hardware Procurement (complex global manufacturing supply chains)
• Recruitment & Contracting (multi-tier labour intermediaries)
• Certain Geographies with lower labour protections

We mitigate these risks through enhanced due diligence and contract clauses, and we reduce layers of subcontracting where feasible.

4) Due Diligence on Suppliers & Partners

• Pre-contract screening: sanctions and adverse media checks; confirmation of compliance with our Supplier Code of Conduct and the Modern Slavery Act.
• Contractual controls: audit rights, flow-down obligations, immediate termination for breaches, and corrective action plans where remediation is possible.
• Ongoing monitoring: annual attestations, KPI reviews, and targeted audits for higher-risk categories.
• Remediation: if risks are identified, we work with suppliers on time-bound corrective actions; where unresolved, we escalate or exit the relationship.

5) People, Culture & Grievance Channels

• Whistleblowing hotline/email accessible to employees, contractors and suppliers; anonymous reporting supported.
• HR grievance procedures with clear, confidential escalation paths.
• No fees charged to workers for recruitment; wages paid directly and on time; clear employment terms.

6) Training & Awareness

• Mandatory induction for all new joiners covering our zero-tolerance stance and how to spot red flags.
• Annual refreshers for procurement, HR, operations, and delivery managers.
• Targeted workshops for supplier-facing teams on risk indicators, interviewing suppliers, and managing remediation plans.

7) Performance Indicators (KPIs)

• 100% of new strategic suppliers signed to the Supplier Code of Conduct.
• 100% completion of modern slavery training for relevant staff annually.
• Risk-based audits completed for all high-risk suppliers each year.
• Zero substantiated incidents of forced labour or trafficking in our operations; all allegations investigated promptly.
• Corrective action plans closed within agreed timelines where issues are identified.

8) Continuous Improvement (2025–2026)

• Enhance supplier onboarding questionnaires with deeper labour standards questions and documentary evidence requests.
• Extend audit coverage to medium-risk categories and randomised spot checks.
• Publish our Supplier Code of Conduct and escalation contacts on our website.
• Strengthen subcontractor transparency requirements in recruitment and facilities contracts.
• Introduce modern slavery risk scoring into quarterly business reviews with strategic suppliers.

9) Governance & Accountability

• Board oversight of policy, risk, and annual statement approval.
• Executive sponsor: Chief Operating Officer (COO) accountable for implementation.
• ESG & Compliance Working Group meets quarterly to review incidents, audit results, training uptake, and supplier attestations.
• Reporting: incidents escalated to the Board; trend analysis shared with leadership and relevant teams.

10) How to Raise a Concern

Concerns can be raised confidentially via our whistleblowing channel at whistleblowing@cloudinindia.com or through HR. We do not tolerate retaliation against anyone who raises a concern in good faith.

11) Policies & Supporting Documents

• Anti-Bribery & Corruption Policy
• Privacy Policy
• Data Breach Policy
• Environmental Policy
• Supplier Code of Conduct (available on request)
• Modern Slavery & Human Trafficking Policy (available on request)

12) Approval

This statement has been approved by the Board of Directors of Cloud in India Limited on July 07, 2025 and will be reviewed and updated annually.