Canada Modern Slavery Act Statement

Report Required by Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act

This report is being made and published in compliance with Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act). This is an original (not revised) joint report for the January 1, 2023 to December 31, 2023 financial reporting year for:

• Spire Global, Inc. – a publicly traded US corporation (NASDAQ: SPIR) (business no. 85-1276957)
• Spire Global Subsidiary, Inc. – a direct US subsidiary of Spire Global, Inc. (business no. 46-0892816)

This report has been approved by the Boards of Directors of Spire Global, Inc. and Spire Global Subsidiary, Inc.

The reporting entities are headquartered in the United States. Spire Global, Inc. also has indirect subsidiaries located in Australia, Canada,1 Germany, Luxembourg, Singapore, and the United Kingdom, all of which are direct subsidiaries of Spire Global Subsidiary, Inc. Spire Global, Inc. and its group of companies (collectively, Spire) also have modern slavery and child labor reporting obligations under the Australia’s Modern Slavery Act 2018 and the United Kingdom’s Modern Slavery Act 2015.

Spire Global, Inc., group companies have a place of business in Canada, do business in Canada and have assets in Canada. Spire’s financial reporting is consolidated, and the group companies have at least $20 million in assets for at least one of their two most recent financial years, have generated at least $40 million in revenue for at least one or two of their most recent financial years, and employ an average of at least 250 employees for at least one of their two most recent financial years.

Spire Global Subsidiary, Inc. does business in Canada and has at least $20 million in assets for at least one of its two most recent financial years and has generated at least $40 million in revenue for at least one or two of its most recent financial years.

The Spire group of companies engage in producing satellites, ground stations and related items as well as other service sectors.

Information Required Under Section 11 of the Act:

Leveraging its proprietary satellite constellation and ground stations, Spire delivers maritime, aviation, weather, and radio frequency intelligence data to commercial and government customers worldwide. Spire’s Space Services business also allows customers to deploy and scale their own constellations using -to-end manufacturing facility, and launch partnership network.

Spire Global UK Ltd., a direct subsidiary of Spire Global Subsidiary, Inc. and an indirect subsidiary of Spire Global, Inc., manufactures satellites in Glasgow, Scotland. Spire Global Subsidiary, Inc. assembles ground station equipment in the United States for deployment in strategic locations worldwide.

Spire’s policies prohibit use of forced and child labor. Spire does not employ forced or child labor. Spire’s standard terms and conditions prohibit its suppliers from using forced and child labor.

Spire buys parts and components such as circuit boards and star trackers for its satellites and parts and components such as cables and antennas for its ground stations.

To prevent and reduce risks of forced and child labor, in 2023 Spire conducted an internal assessment of risks of forced and child labor in the organization’s activities and supply chains, audited suppliers, and monitored suppliers. In the satellite industry, particularly satellite manufacturing, risks arise in connection with mining raw materials, specifically gold and tin, used to manufacture satellite and ground station parts and components such as electronics and soldered items, respectively.

Approximately 90-95% of Spire’s suppliers are located in the European Union, United Kingdom and the United States. Approximately 90-95% of Spire’s satellite parts are purchased directly from the manufacturer. All key suppliers (i.e. those who receive the largest number of orders for the largest number of satellite parts) are located in the UK. Spire’s EU and UK electronic suppliers obtain gold and tin from approved sources and must adhere to the same forced labor/child legal standards as Spire, including in their supply chains.

Most of Spire’s satellite supplier relationships are long term. New suppliers are vetted by Spire’s Supply Chain, Quality & Engineering teams and must provide information about forced and labor and whether the supplier conducts due diligence on its suppliers. Spire has not identified flags suggesting forced or child labor concerns in connection with its existing or new suppliers.

In 2023, Spire surveyed its first-tier suppliers regarding forced and child labor practices, finding no concerns. Also in 2023, Spire’s Procurement team visited key satellite suppliers covering approximately 65% of the satellite parts. On-site visits included shop floor visits. Site visits did not identify any concerns regarding use of forced or child labor.

Because Spire has not identified any forced or child labor, it has not taken measures to remediate any forced or child labor. It also has not identified instances requiring and therefore has not taken measures to remediate the loss of income to the most vulnerable families that results from any measure taken to eliminate the use of forced or child labor in its activities and supply chains.

Currently, Spire does not provide training to its employees on forced or child labor. Given that Spire’s current supplier relationships are concentrated with entities located in jurisdictions in which legal, including customs, requirements require adherence to forced and child labor standards for their operations and supply chains, at this time Spire has not implemented policies and procedures specifically to assess its effectiveness in ensuring that forced and child labor are not being used in its activities and supply chains.

Attestation: In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity or entities listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above.

Full name: Boyd Johnson
Title: Chief Legal Officer
Date: May 29, 2024
Signature:

I have the authority to bind Spire Global, Inc. and Spire Global Subsidiary, Inc.