Modern Slavery & Human Trafficking Policy

1. Introduction

QantX Ltd is committed to acting ethically and with integrity in all its business activities and relationships. We are equally committed to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere in our own organisation or supply chains.

This policy sets out our approach to identifying and managing the risks of modern slavery and human trafficking and reflects our obligations under the Modern Slavery Act 2015 and applicable UK law.

2. Scope

This policy applies to all individuals working for or on behalf of QantX Ltd in any capacity, including employees, directors, officers, agency workers, contractors, consultants, and any other third parties acting under our instruction or on our behalf.

3. What Is Modern Slavery?

Modern slavery is an umbrella term that encompasses a range of serious crimes and violations of fundamental human rights, including:

• Slavery — exercising powers of ownership over a person
• Servitude — the obligation to provide services, imposed by coercion
• Forced or compulsory labour — work or service extracted from any person under the threat of a penalty and for which the person has not offered themselves voluntarily
• Human trafficking — arranging or facilitating the travel of another person with a view to their exploitation
• Child labour — the employment of children in a manner that is harmful to their physical, mental, social, or educational development

Modern slavery can affect people of any age, gender, or nationality. It can occur in any sector or industry, including the financial and professional services sector in which QantX Ltd operates.

4. Our Business and Supply Chains

QantX Ltd is an investment firm focused on IP-led technology investments across deep tech, cleantech, life sciences, advanced materials, and related sectors. Our operations are based in the United Kingdom.

As an investment firm, our direct supply chain is relatively limited in scope. Our principal third-party relationships include:

• Professional advisers (legal, accounting, tax, and regulatory)
• Technology and software providers
• Office facilities and infrastructure providers
• Financial intermediaries and custodians

Although the risk of modern slavery in our direct operations is assessed as low, we recognise that our portfolio companies and investee businesses may operate in sectors and geographies with a higher risk profile. We take this seriously and factor human rights considerations into our investment evaluation and ongoing engagement.

5. Our Commitments

QantX Ltd commits to the following:

• Not knowingly supporting or engaging with any business or individual involved in modern slavery or human trafficking
• Conducting proportionate due diligence on new and existing suppliers and business relationships
• Taking reasonable steps to identify and address modern slavery risks in our supply chain
• Maintaining clear and accessible reporting mechanisms for concerns
• Reviewing and improving our processes and controls on an ongoing basis
• Considering modern slavery risks as part of our investment due diligence and ESG assessments

6. Due Diligence

6.1 Supplier and Counterparty Assessment

We conduct proportionate due diligence on third parties with whom we engage. This includes reviewing the nature of their business and operations, their geographic footprint, and any publicly available information that may indicate elevated modern slavery risk. For higher-risk relationships, we may request additional information, including evidence of their own modern slavery policies and controls.

6.2 Investment Due Diligence

As part of our investment evaluation process, we consider human rights and labour standards where material to the risk profile of an investee company. This is particularly relevant for businesses operating in sectors or geographies with known risks of forced labour or exploitative working conditions. We engage with management teams on these issues and expect portfolio companies to adopt and maintain appropriate policies.

6.3 Ongoing Monitoring

We monitor our principal supplier relationships on an ongoing basis and will revisit our risk assessments where material changes occur in a counterparty’s business or circumstances.

7. Risk Assessment

We assess the risk of modern slavery in our operations and supply chain having regard to:

• The sector and industry in which counterparties operate
• The geographic locations in which work is performed or goods are sourced
• The nature of the services provided (e.g. labour-intensive services carry a higher inherent risk)
• The size, structure, and governance of the counterparty
• Any prior incidents, adverse media, or regulatory findings relating to the counterparty

On the basis of this assessment, we consider the risk of modern slavery in QantX Ltd’s direct operations and immediate supply chain to be low. We will nevertheless continue to apply appropriate vigilance and update our assessment as our activities and supply chain evolve.

8. Policies and Governance

This policy is reviewed annually by senior management and updated to reflect changes in law, best practice, or our own operations. It has been approved by the senior leadership of QantX Ltd.

This policy should be read alongside our other related policies, including:

• Whistleblowing Policy
• Code of Conduct
• ESG & Responsible Investment Policy
• Anti-Bribery & Corruption Policy

9. Training and Awareness

All employees and relevant personnel are expected to familiarise themselves with this policy. We provide appropriate guidance on recognising the signs of modern slavery and the steps to take if a concern is identified. Awareness of modern slavery risks forms part of our induction process for new staff and is reinforced periodically.

10. Reporting Concerns

If you believe that modern slavery or human trafficking is occurring anywhere in our business or supply chain, or if you have reasonable grounds to suspect it, you should report your concern immediately. Reports can be made to any member of senior management or via our whistleblowing procedure, which allows for confidential and, where appropriate, anonymous reporting.

We take all reports seriously and will investigate promptly. No individual will suffer any detriment for raising a concern in good faith. Anyone who is found to have participated in modern slavery or human trafficking, or who knowingly facilitates it, will be subject to disciplinary action, which may include termination of employment or contract and referral to the relevant authorities.

11. Breaches of This Policy

Any supplier, contractor, or third party that is found to be involved in modern slavery or human trafficking will have their relationship with QantX Ltd terminated. We will report confirmed cases of modern slavery or human trafficking to the relevant law enforcement authorities.

12. Legislative Compliance

This policy is designed to comply with the Modern Slavery Act 2015 and associated guidance issued by the Home Office. QantX Ltd will publish a Modern Slavery Act Transparency Statement on its website in accordance with section 54 of the Act where required to do so by law, or on a voluntary basis where it considers publication to be in the public interest.