Modern Slavery Statement

Modern Slavery and Human Trafficking Statement

Fiscal Year 2025 (Ended October 31, 2025)

Introduction

WoveCX Inc. ("WoveCX") is a leading Canadian-based software company headquartered in Toronto, Ontario, with global operations spanning North America, Europe, Asia, and Africa. Founded in 2025, we develop and provide cloud-based platforms that enable businesses to manage international labor hiring, streamline supply chain logistics, and facilitate global product sourcing and shipping. Our workforce exceeds 10 employees and contractors across 2 countries, and our platform supports hundreds of users in recruiting and deploying labor forces worldwide. In FY2025, WoveCX sourced hardware components, office supplies, and merchandise from over 10 suppliers in more than 5 countries to meet customer demands for integrated software-hardware solutions.

This Statement is prepared pursuant to Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (2024), the UK's Modern Slavery Act (2015), and Australia's Modern Slavery Act (2018). It outlines the steps WoveCX has taken during FY2025 to prevent modern slavery and human trafficking in our operations and supply chains. Modern slavery encompasses forced labor, child labor, human trafficking, slavery, servitude, debt bondage, and exploitative practices that deprive individuals of their freedom. WoveCX has a zero-tolerance policy toward these practices and is committed to upholding human rights in alignment with the United Nations Guiding Principles on Business and Human Rights (UNGPs), the International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work, and the OECD Due Diligence Guidance for Responsible Supply Chains. We do not tolerate modern slavery in any form and actively work to eradicate it from our direct operations, supply chains, and the ecosystems enabled by our platform.

In FY2025, no instances of modern slavery or human trafficking were identified in our operations or supply chains.

Our Structure and Supply Chain

WoveCX's business model involves software development, international employment, platform-enabled labor hiring, and global sourcing/shipping of products such as security equipment, IoT devices, and building materials materials. Our supply chain includes:

Direct suppliers: Providers of IoT hardware, software licenses, professional services (e.g., software programming, consulting, recruitment agencies), office facilities, travel, and merchandise (e.g., promotional items).

Indirect supply chain: Sub-tier suppliers for raw materials and manufacturing, primarily in high-volume sourcing regions like Asia and Eastern Europe.

Platform ecosystem: Users of our hiring platform, who engage third-party labor providers; while we do not directly control user actions, we promote ethical guidelines and monitor for red flags.

Policy Commitments

WoveCX's commitment to human rights is embedded in our core governance framework:

Global Human Rights Policy: Prohibits forced, bonded, or child labor; ensures fair wages, safe working conditions, freedom of association, and non-discrimination. It aligns with the UN Universal Declaration of Human Rights, ILO Core Conventions, and UNGPs, applying to all employees, contractors, suppliers, and platform users.

Code of Business Conduct and Ethics: Requires annual acknowledgment by all employees and contractors, emphasizing ethical decision-making, anti-corruption, and reporting of violations without retaliation.

Supplier Code of Conduct: Mandates suppliers to prohibit modern slavery, conduct human rights due diligence, and cascade requirements to sub-tiers. Contracts include audit rights, termination clauses for non-compliance, and representations of slavery-free operations.

Platform User Guidelines: Encourage ethical labor practices, with tools for users to verify provider compliance (e.g., background checks, fee transparency).

These policies are reviewed annually by our Board of Directors' Sustainability and Risk Committee, with input from internal stakeholders including Legal, Procurement, HR, and Platform Operations.

Due Diligence Processes

WoveCX implements a risk-based due diligence framework to identify, assess, and mitigate modern slavery risks:

Supplier Onboarding: All new suppliers complete a self-assessment questionnaire on ESG factors, including modern slavery risks, followed by enhanced due diligence for high-risk categories (e.g., recruitment agencies, manufacturing).

Ongoing Monitoring: We use third-party platforms (e.g., Integrity Next) to screen suppliers for adverse media, regulatory violations, and risk indicators. In FY2025, 85% of suppliers (n=425) were assessed, with 100% of high-risk ones undergoing desk reviews.

Audits: Conducted 150 supplier audits (including 50 unannounced), aligned with Responsible Business Alliance (RBA) and Sedex standards, covering labor practices, recruitment fees, and worker conditions. Platform providers are evaluated via user feedback and periodic compliance checks.

Collaboration: We participate in industry initiatives like the Responsible Labor Initiative and partner with NGOs for supply chain mapping.

Risk Assessment

Risks are assessed annually using external indices (e.g., Global Slavery Index, U.S. Department of Labor reports) and internal data, focusing on:

Geographic and Sectoral Risks: Higher exposure in Asia (e.g., electronics manufacturing) and labor migration corridors for platform-enabled hiring.

Salient Issues: Forced labor via recruitment fees, migrant worker exploitation, and child labor in sub-tier sourcing for shipped products. Low risk in direct operations due to robust HR controls.

In FY2025, we conducted a full supply chain risk mapping, prioritizing 20% of suppliers as high-risk based on location, industry, and migrant worker usage. No significant risks were identified in platform user ecosystems, but we enhanced monitoring tools for fee transparency.

Supplier and Platform Management

Suppliers must comply with our Supplier Code from contract inception, with performance tied to business awards and renewals. We prefer long-term relationships with audited, low-risk partners and require sub-tier transparency. For platform users:

We provide resources like ethical hiring toolkits and integrate risk alerts into the platform.

High-risk user engagements trigger reviews, with suspension for verified violations.

In FY2025, we terminated relationships with 5 suppliers (2% of total) due to audit findings on labor documentation, requiring corrective action plans (CAPs) first.

Remediation and Grievance Mechanisms

WoveCX prioritizes worker-centered remediation:

Investigation: Reports are handled via our 24/7 anonymous Ethics Hotline (third-party managed, multilingual) or direct channels to HR/Compliance, with investigations completed within 30 days. No retaliation policy is strictly enforced.

Corrective Actions: CAPs address root causes, with timelines (e.g., 90 days for major findings) and verification audits. Remedies include fee repayments (e.g., $150,000 reimbursed in FY2025 to 250 workers) and supplier capacity-building.

Platform Grievances: Users can report issues via in-app tools, escalating to WoveCX for mediation.

In FY2025, we resolved 12 grievances (none slavery-related) with 100% worker satisfaction via follow-up surveys.

Training and Awareness

Training fosters a culture of vigilance:

Employees and Contractors: Mandatory annual Code of Conduct training (98% completion rate), plus targeted modules on modern slavery risks for Procurement, HR, and Platform teams (covering 500+ participants, 12 hours total).

Suppliers: 300+ high-risk suppliers completed online training on responsible recruitment and human rights, in partnership with ILO resources.

Platform Users: Free webinars and guides on ethical hiring reached 10,000+ users.

Content was updated in FY2025 based on Public Safety Canada's risk reports.

Measuring Effectiveness

We evaluate program effectiveness through KPIs:

Audit compliance: 92% of suppliers achieved high scores (≥85/100), up 5% from FY2024.

Training completion: 98% overall.

Grievance resolution: 100% within timelines; zero modern slavery reports.

Incident tracking: No losses from slavery elimination efforts.

Annual reviews by the Sustainability Committee incorporate stakeholder feedback and benchmark against peers. Continuous improvement includes AI-driven risk monitoring pilots.

Looking Forward

WoveCX remains dedicated to evolving our practices, deepening supplier engagements, and advocating for ethical standards in the tech and labor sectors. We invite stakeholder input to strengthen our efforts.