UK Modern Slavery Act Statement

May 23, 2023

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.”

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. As a global business that sources from international suppliers, Spire recognizes the concern for potential human trafficking in global supply chains. Spire is committed to compliance with all applicable labor laws, including the UK’s Modern Slavery Act.

Spire expects employees to abide by applicable labor laws. 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.

Spire also requires its business partners to comply with relevant labor laws and, where applicable, to the relevant provisions of the UK Modern Slavery Act. Spire conducts due diligence on its vendors and suppliers; qualifications include adherence to the UK Modern Slavery Act and a prohibition on human trafficking, child labor, slavery and slave labor. Spire’s vendor terms and conditions include provisions prohibiting human trafficking, child labor, slavery and slave labor.

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