UK Modern Slavery Act Statement

June 25, 2024

This statement is made pursuant to Section 54, Part 6 of the UK Modern Slavery Act 2015 and sets out the steps Spire has taken to ensure that slavery and human trafficking are not taking place in its business.

Spire recognizes its social responsibility in the communities in which it operates. As stated in its Code of Business Conduct and Ethics, Spire “strives to conduct its business activities and operations in a manner that promotes protection of people.”

1. Organizational Structure and Supply Chains

Spire Global UK Ltd. Is an indirect subsidiary of Spire Global, Inc. Spire Global, Inc. is a publicly traded US company (NYSE: SPIR) with operations in Australia, Canada, Germany, Luxembourg, Singapore, the United Kingdom, and the United States. 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 Spire’s space platform, global ground station network, end-to-end manufacturing facility, and launch partnership network.

Spire manufactures satellites in Glasgow, Scotland. Spire assembles ground station equipment in the United States for deployment in strategic locations worldwide.

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. 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.

2. Due Diligence; Risk Assessments and Management; KPIs; and Training

Spire opposes and prohibits the use of human trafficking, child labor, slavery and slave labor, and it expects the same from its business partners and suppliers. To prevent and reduce risks of modern slavery, Spire conducts internal assessments, audits suppliers, and monitors 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. Spire requires its suppliers to adhere to the requirements outlined in the UK Modern Slavery Act. Spire’s vendor terms and conditions include provisions prohibiting human trafficking, child labor, slavery and slave labor.

As noted above, Spire’s suppliers are located predominantly in the UK and EU. 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.

At this time, Spire has not identified operations or direct suppliers posing modern slavery risks, therefore it has not developed specific modern slavery KPIs. Spire provides relevant Code of Business Conduct and Ethics training to its employees and has implemented multiple venues through which its employees can report concerns regarding potential misconduct without fear of retaliation.

This statement has been approved by the Board of Directors for Spire Global UK Limited.