Modern Slavery Statement

This Statement is made by Etech Global Services, LLC on behalf of itself and its subsidiaries (collectively "Etech," "we," "us") pursuant to section 54(1) of the United Kingdom Modern Slavery Act 2015, and is issued consistent with the Australia Modern Slavery Act 2018, the California Transparency in Supply Chains Act of 2010, and the Canada Fighting Against Forced Labour and Child Labour in Supply Chains Act. It sets out the steps Etech has taken and continues to take to prevent modern slavery and human trafficking in our business and supply chains.

Etech does not tolerate modern slavery, human trafficking, servitude, forced or compulsory labor, child labor, or debt bondage in any part of our operation or supply chain. We expect the same standard from every supplier and subcontractor we engage.

This Statement covers the financial year ending December 31, 2025, and supersedes all prior Etech statements. It applies to Etech Global Services, LLC and every operating entity under common control, including entities in the United States, Jamaica, and India. Where local law imposes additional or more specific disclosure, the local entity satisfies those requirements through this Statement, a local attachment, or the relevant local registry filing.

• United Kingdom: issued consistent with section 54 of the Modern Slavery Act 2015, even where the threshold does not strictly apply, because Etech serves clients in the United Kingdom.
• Australia: issued consistent with the Modern Slavery Act 2018 (Cth) reporting criteria for the covered entity's financial year, where applicable.
• California: issued consistent with the California Transparency in Supply Chains Act of 2010 (Cal. Civ. Code § 1714.43).
• Canada: issued consistent with the Fighting Against Forced Labour and Child Labour in Supply Chains Act (S.C. 2023, c. 9) for any Etech entity meeting the reporting thresholds.

Etech Global Services is a contact center operator headquartered at 1903 Berry Drive, Nacogdoches, Texas 75964, with operating sites in the United States, Jamaica, and India. We provide customer care, sales and revenue operations, quality and analytics, back office services, and voice AI services to enterprise clients across telecommunications, insurance, healthcare, financial services, automotive, retail, education, technology, and public sector. We develop our own performance management and voice AI platforms through ETSLabs, our applied AI division of 250 engineers.

Etech has operated continuously since 2003. The company has documented zero material breaches of data or compliance obligations across that 22-year period.

Etech directly employs a workforce of approximately 4,000 across our sites. Our people are not staffed through labor brokers or recruitment intermediaries that charge workers for placement. Our workforce profile is as follows:

• United States: Nacogdoches, Rusk, Lufkin, Palestine, and San Angelo (Texas), with additional US presence.
• Jamaica: Montego Bay.
• India: Gandhinagar and Vadodara, Gujarat.
• Average tenure of 6.3 years, with monthly attrition below 5 percent.
• Operating model built on servant leadership and internal promotion pipeline.

Etech operates in the services sector. Our supply chain is relatively narrow compared with a manufacturing or retail organization. The categories of third-party spend most relevant to this Statement are:

• Facilities and janitorial services at our operating sites in the United States, Jamaica, and India.
• Security services at our operating sites.
• Physical IT hardware (endpoints, networking equipment) and peripherals procured through authorized resellers.
• Professional services including legal, audit, staffing agencies for specialist technical roles, and training vendors.
• Telecommunications carriers and cloud-infrastructure providers.
• Subcontractors engaged for specialist program work, retained only where a client's scope requires capability Etech does not deliver directly, and only under written subcontractor terms that flow down this Statement's standards.

Etech conducts an annual modern-slavery risk assessment across our own operations and our tier-one supply chain. The assessment is led by the Chief Compliance Officer with input from Global HR, Security, Legal, and Site Operations. The 2025 assessment produced the following residual-risk summary after controls:

The following policies form the Etech human-rights control framework. Each is reviewed annually and approved by the responsible executive.

• Code of Conduct: applies to every Etech employee, director, and officer.
• Human Rights Policy: commits Etech to the UN Guiding Principles on Business and Human Rights.
• Anti-Slavery and Human Trafficking Policy: prohibits any form of modern slavery or human trafficking in our operations or supply chain.
• Whistleblower and Grievance Policy: provides anonymous channels for reporting any concern, with non-retaliation commitment.
• Supplier Code of Conduct: flows the same standards to every supplier.
• Equal Employment Opportunity Policy: prohibits discrimination.
• Global HR Standards: govern recruitment, compensation, working hours, overtime, and termination consistent with local labor law and ILO core conventions.

Etech applies the following recruitment standards across every operating location:

• Direct hire. Etech does not rely on third-party labor brokers for line-of-business hiring. Specialist roles where an agency is used (for example, certain senior technical searches) are governed by a written agency agreement and the agency may not charge any fee to the candidate.
• No worker-paid fees. Under no circumstance is a worker required to pay a recruitment fee, deposit, or equivalent as a condition of employment. If a worker in our supply chain has paid a fee to secure a position on an Etech account, the supplier is required to repay the worker in full and the incident is reported to the Compliance Committee.
• Age verification. Every hire is age-verified against government-issued identification. Etech does not employ anyone under the minimum working age in the jurisdiction of hire, and does not employ anyone under 18 in any role that would be hazardous under ILO Convention 182.
• Passport and document retention. Etech does not retain any worker's original identity document. Identity documents are verified and returned to the worker on the same day.
• Freedom of movement. Workers are free to leave their employment on notice. Dormitory arrangements are not used. No worker is subject to restriction of movement by Etech.
• Contracts in the worker's language. Employment contracts are provided in the worker's primary language where legally required and as a default practice in India and Jamaica.

Etech applies tiered due diligence to new and existing suppliers. The depth of diligence is calibrated to category risk. At minimum, every supplier above Etech's materiality threshold is required to:

• Acknowledge and sign the Etech Supplier Code of Conduct.
• Complete the annual Modern Slavery Declaration questionnaire.
• Warrant compliance with applicable anti-slavery and anti-trafficking law.
• Flow these obligations down to their own supply chain.
• Permit Etech or its nominated third party to audit against the Supplier Code of Conduct on reasonable notice.

Higher-risk categories (facilities, security, staffing, and physical IT hardware) are subject to on-site verification on a rolling cycle. Etech reserves the right to terminate any supplier that fails to remediate a material finding within an agreed time.

Every Etech employee completes modern-slavery awareness training during onboarding. Refresher training is delivered annually. Role-based deep-dive training is delivered to the following functions:

• Procurement and vendor management: supplier due-diligence procedures, red flags, escalation path.
• Human resources and recruiting: recruitment-standards application, age verification, fee-prohibition enforcement.
• Site leadership: indicators of forced labor, grievance handling, whistleblower route.
• Compliance and internal audit: annual risk-assessment methodology, audit protocol, reporting-line escalation.

Training delivery is tracked in the Etech learning management system. The Compliance Committee receives a quarterly completion report.

Any Etech employee, contractor, supplier, or third party may report a suspected modern-slavery or human-trafficking concern through any of the following channels. Reports may be made anonymously, and Etech maintains a strict non-retaliation policy.

• Internal email: ethics@etechgs.com
• Compliance Office: compliance@etechgs.com
• Written: Compliance Committee, Etech Global Services, LLC, 1903 Berry Drive, Nacogdoches, Texas 75964, United States
• Phone: +1 (936) 559-2200, ask for the Compliance Office
• Anonymous third-party line as disclosed in the employee handbook

If an instance of modern slavery or human trafficking is identified in Etech's operations or supply chain, our remediation approach follows the UN Guiding Principles on Business and Human Rights:

• Immediate action to remove any affected worker from harm and secure access to support services.
• Reimbursement of any recruitment fees paid by workers, borne by the supplier.
• Root-cause investigation led by the Compliance Committee.
• Corrective action plan with the supplier, with defined timelines and on-site verification of completion.
• Termination of the supplier relationship if remediation fails or the finding is systemic.
• Reporting to local authorities where required by law, subject to worker safety and consent.

Etech measures the effectiveness of this program against the following indicators, reported to the Compliance Committee quarterly and to the executive leadership team annually:

• Percentage of employees completing annual modern-slavery training (target: 100 percent).
• Percentage of material suppliers with signed Supplier Code of Conduct and current Modern Slavery Declaration (target: 100 percent).
• Number of supplier on-site audits completed in the year against plan.
• Number of concerns reported through each whistleblowing channel, with investigation status and outcome.
• Number of remediation actions opened, closed, and outstanding.
• Employee tenure and attrition by site, as leading indicators of labor stability.

During the reporting year ending December 31, 2025, Etech identified no confirmed instances of modern slavery or human trafficking in our operations or supply chain.

Accountability for this Statement and the underlying program rests with the Etech Board and is delegated to the Chief Compliance Officer. The Compliance Committee, chaired by the Chief Compliance Officer and attended by the Chief Executive Officer, Chief Operating Officer, Chief People Officer, and General Counsel, meets quarterly to review the program and the effectiveness indicators above.

Questions about this Statement, requests for the signed PDF, or requests for supplier due-diligence documentation should be directed to: