Modern Slavery & Human Trafficking Statement
Cleo AI UK Ltd
Financial Year: 22 August 2025 – 31 August 2026
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the
steps taken by Cleo AI UK Ltd (“Cleo” or “the Company”) during the financial year ending 31
August 2026 to prevent modern slavery and human trafficking in our business and supply
chains.
Our Business and Structure
Cleo AI UK Ltd is a UK-incorporated company and a wholly owned subsidiary of Cleo AI Ltd, its
parent company.
We provide AI-powered digital financial tools and services through a mobile application.
Our business model is technology-driven. We operate from office and remote environments and
do not manufacture physical goods. Our supply chain primarily consists of technology and
service providers, including:
Cloud hosting and infrastructure providers
Software and technology vendors
Payment and financial services partners
External audit providers
IT hardware and equipment suppliers
Our Commitment
Cleo has zero tolerance for slavery, servitude, forced labour, and human trafficking.
We are committed to:
Conducting our business in an ethical and transparent manner
Complying with applicable employment and human rights laws
Taking proportionate steps to identify and manage risks in our supply chain
Expecting our suppliers and business partners to uphold similar standards
Governance and Policies
Oversight of modern slavery risk forms part of our broader governance and compliance
framework.
We maintain policies and controls that support responsible business conduct, including:
Code of Conduct
Human Resource Security Policy
Third-party onboarding and due diligence processes
We are committed to fair employment practices and comply with applicable UK employment
legislation in relation to pay, working time, and right-to-work verification.
Responsibility for oversight sits with the Board of Directors and designated members of senior
management.
Risk Assessment and Due Diligence
We take a risk-based approach to third-party engagement.
As part of onboarding and ongoing vendor management processes, we may undertake
proportionate due diligence activities, including screening and assessment of supplier risk
profiles.
As applicable, our contracts may include provisions requiring suppliers to comply with applicable
laws, including those relating to modern slavery and human trafficking.
Given the nature of our operations, we consider the overall risk of modern slavery within our
direct business activities to be low. We remain attentive to potential risks within extended
service supply chains.
Reporting Concerns
Employees and third parties are encouraged to raise concerns through established internal
reporting channels. Reports are reviewed and addressed in accordance with internal
governance procedures.
Ongoing Development
As the Company continues to grow, we will review and, where appropriate, enhance our policies
and risk management processes to ensure they remain proportionate to the scale and
complexity of our operations.
This statement will be reviewed annually and updated as appropriate.
Approval
This statement was approved by the Board of Cleo AI UK Ltd .
Signed:
Barney Hussey-Yeo
Director
Cleo AI UK Ltd