Policy

modern-slavery-statement

Modern Slavery and Human Trafficking Statement

AlphaGen Holdings Limited ("AlphaGen")

Companies House no. 17084844 — registered in England and Wales

Statement period: financial year ending [TO BE INSERTED on

first publication]

Effective date: 2026-04-27

Version: 1.0.0

Contact: legal@alpha-gen.ai

This statement is published voluntarily. AlphaGen's annual

turnover is currently below the £36 million threshold at which

section 54 of the Modern Slavery Act 2015 would mandate

publication. We publish anyway because:

Our enterprise customers expect a public statement.
The discipline of writing it informs our supplier-management

practices.

We want to commit to the threshold-mandated regime now,

while we are still small enough to build the right habits.

We will continue to publish updated statements annually,

approved by the Board, signed by a director, and posted to our

website footer.

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1. Our business

AlphaGen is a UK-headquartered AI-software company operating the

AlphaGen AutoAnnotation System — a privacy-by-design platform

for processing video and audio into structured annotations,

geometry, and world-state data. Our customers are commercial

organisations (research, healthcare, robotics, sports analytics,

insurance) that need high-quality annotated data to train or

evaluate their own systems.

Our supply chain is small and largely software-based:

Cloud infrastructure providers (Amazon Web Services,

Google Cloud Platform, Microsoft Azure) — see the

sub-processor list at docs/legal/privacy/subprocessors.md.

AI / model providers (Anthropic, OpenAI, Google) for

Pass 4 LLM synthesis under contract.

Software-as-a-service tools for engineering, support, and

business operations (e.g. GitHub, Datadog, Stripe, Notion,

Slack, Vault).

Professional advisors (legal, accounting, audit, security

testing) retained as needed.

Hardware suppliers for GPUs and developer laptops (limited;

off-the-shelf consumer / enterprise hardware).

Content contributors and HITL operators — paid annotators

who consent to the platform's terms before contributing.

We do not engage in:

Mass low-wage data-labelling subcontracting in low-income

jurisdictions.

Any manufacturing, agriculture, mining, fishing, garment, or

hospitality activity — sectors typically associated with

modern-slavery risk.

Recruitment of unaccompanied migrant labour or any worker

through an unregulated recruitment intermediary.

The risk profile of our supply chain is therefore concentrated

in: (a) cloud-infrastructure operations (where the suppliers'

own anti-slavery programmes apply); (b) the small number of

hardware items we purchase; and (c) any future expansion into

HITL operator pools that include workers in higher-risk

jurisdictions.

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2. Our policies

The following internal policies are in place and enforced:

Code of Conduct — applies to all directors, employees,

contractors, and on-site visitors. Prohibits any form of

forced labour, child labour, or human trafficking.

Anti-Bribery Policy — see

docs/legal/internal/anti-bribery-policy.md. Forbids

payments to facilitate any unlawful labour practice in our

supply chain.

Equal Opportunities Policy — see

docs/legal/internal/equal-opportunities-policy.md. Commits

to fair employment regardless of any protected characteristic.

Recruitment Policy — every hire is verified against the

legal right to work in the relevant jurisdiction; recruitment

fees are paid by AlphaGen, never by the candidate.

Whistleblowing Policy — included in the Disciplinary &

Grievance Procedure

(docs/legal/internal/disciplinary-grievance-policy.md).

Allows confidential, retaliation-free reporting of suspected

modern-slavery, bribery, or fraud incidents.

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3. Due diligence

For each new supplier or sub-processor we:

Assess the supplier's modern-slavery risk profile based on

sector, jurisdiction, and any public reports.

Require, in our standard supplier terms, a representation

that the supplier complies with the Modern Slavery Act 2015

(or local equivalent) and has its own anti-slavery

commitments documented.

For any supplier above the £36 million threshold, review

their published Modern Slavery Statement before contract

signature.

For any supplier below the threshold but in a higher-risk

sector, request a written confirmation of anti-slavery

commitments and the right to terminate on credible evidence

of breach.

We re-review the supplier list quarterly as part of our

sub-processor governance.

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4. Risk assessment

Our current risk assessment is:

|---|---|---|---|

| Hardware suppliers | Medium (electronics supply chains have known issues) | Low | We buy small quantities through tier-1 retailers in the UK and EU; we are not a meaningful buyer in the global supply chain but track our suppliers' published statements. |

| Future HITL operator expansion | Potentially medium if we add operators in higher-risk jurisdictions | TBD | Any expansion requires Responsible AI Review Board sign-off including a labour-conditions assessment. |

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5. Training

All staff complete an annual modern-slavery and ethical-business

module as part of our compliance training. Engineering staff who

manage supplier onboarding receive an additional module on

supply-chain due diligence.

Training completion is tracked centrally and reported to the

Board annually.

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6. Effectiveness

We measure the effectiveness of our anti-slavery programme

through:

100% supplier coverage: every active supplier has an

attestation in our records or a public statement we have

reviewed.

Zero incidents: no credible report of modern-slavery in

our supply chain to date.

Whistleblowing channel uptake: the channel is open and

documented. We do not take low utilisation as evidence of

absence of issues; we actively communicate the channel's

existence at all-hands meetings.

We will report against these measures in next year's statement.

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7. Approval

This statement was approved by the Board of Directors of

AlphaGen Holdings Limited on 2026-04-27 and signed on its

behalf by the Director listed below.

It will be reviewed annually and re-approved by the Board at

least once every 12 months.

Signed:

[TO BE COMPLETED on first publication]

[Director name]

[Director title]

[Date]

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Document control

|---|---|---|---|

| 1.0.0 | 2026-04-27 | AlphaGen Legal | Initial voluntary statement; AlphaGen is below the £36 m s.54 threshold but commits to publication to support enterprise customer due-diligence requirements. |