Modern Slavery Statement

Modern Slavery Statement for the Financial Year ended December 31, 2019

This statement is made pursuant to s.54 of the United Kingdom’s Modern Slavery Act 2015 and sets out the steps that Kubernets Inc. has taken during the 2019 financial year to ensure that modern slavery and human trafficking are not taking place within our business or supply chain.

Kubernets Inc has a zero-tolerance approach to any form of modern slavery in its business and supply chains. Modern slavery encompasses slavery, servitude, human trafficking and forced labour. We are committed to acting ethically and with integrity and transparency in all business dealings and reject any form of modern slavery or human trafficking taking place within our business or our supply chain.

This statement covers these entities within the Kubernets Inc (collectively, “Kubernets Inc”): Kubernets Inc, Kubernets Inc Anpartsselskab, Kubernets Inc besloten vennootschap, Kubernets Inc Uganda LTD, Kubernets Tech Academy. Kubernets Technologies Zambia, Kubernets Inc UK LTD, Kubernets Inc canada.

Our Business

Kubernets Inc is an IT outsourcing, Software Development and Engineering Services Company. Our vast experience gives us the resources we need to deliver the best value to customers. We offer services for enterprises, small businesses, consumers Organisations and startups. Outsourcing operations are located at in Orlando Florida where we provide Talent training under Kubernets Tech Academy and also place our software engineers to operate with our partners as dedicated remote development team members. Kubernets Inc has grown and become an international corporation and has offices in Uganda, Zambia, Netherlands, United States.

Our Supply Chains

Part of our focus is training, recruiting and identifying talent. On the other hand we also focus of software development and engineering for the smooth operation of any international business – including IT and other office and building services, equipment and utilities. Our supply chains also include suppliers of event spaces for conferences and professional services from our lawyers, software development engineer, accountants, consultants and other advisors. Kubernets Inc is mindful that, particularly across certain parts of the African continent, it operates in locations where the prevalence of modern slavery and human trafficking abuses is statistically higher than average. To date, Kubernets Inc is pleased to confirm that no such abuses have been identified in its business or supply chains in any of our locations.

Policies to Prevent Modern Slavery and Human Trafficking

Given the nature of our business, Kubernets Inc has comparatively limited procurement activities (talent acquisition and Outsourcing aside). Nevertheless, the company takes a robust approach to determining which suppliers it contracts with and is not prepared to maintain business relations with any supplier found to have committed, or been involved with, modern slavery, human trafficking or forced labour abuses. Our opposition to modern slavery and human trafficking is codified in our Employee Handbook, which also provides for incident reporting, and reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to eliminate, as far as possible, the risk of modern slavery and human trafficking taking place anywhere in our business or supply chains.

By way of example, steps we have taken to help ensure modern slavery and human trafficking are not taking place in our business or supply chain include:

1. Global Procurement Policy We have a comprehensive procurement policy in place to regulate how we deal with our global suppliers in a well-managed, fair and ethical manner. This incorporates a strict employee code of conduct and whistleblowing procedure so that any malpractice can swiftly be dealt with and resolved. It also provides for an organized tracking system of vendors and periodic audits of vendor and procurement procedures to ensure compliance. 2. Vendor Code of Conduct Our suppliers are contractually obligated to comply with our vendor code of conduct. This code requires compliance with local employment laws and diversity practices, and expressly prohibits child labour, discriminatory treatment of workers, and other forms of modern slavery and forced labour or involuntary servitude. 3. Adult Hiring Policy Our adult hiring policy expressly prohibits the use of child labour, forced labour and the exploitation of children in our global operations. Notwithstanding any local laws permitting employment at a lower age, kubernets Inc does not hire employees below the age of 18.

Our compliance, audit and legal teams are involved in ensuring this process works and will monitor it regularly, adapting as necessary to the changing needs of our business.

Training: To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and in our supply chains, where appropriate, we will be asking our vendors to provide training to their staff and suppliers.

Approval: This statement constitutes Kubernets Inc’s modern slavery and human trafficking statement for the financial year ending December 31, 2019 as approved by the Kubernets Inc. Board of Directors (“Board”) on behalf of Kubernets Inc group on January 20, 2020. Signed on the Board’s behalf by: Emmanuel N. Christian- President, Kubernets Inc. for and on behalf of itself and the Kubernets Inc group.


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