1. Statement
   

   This statement is prepared by Flatirons Solutions, Inc., on behalf of itself and its subsidiaries (hereinafter “Flatirons”) as required under section 54 of the U.K. Government’s Modern Slavery Act of 2015 (MSA) and FAR 52.222-50 Combating Trafficking in Person. This statement has been prepared in compliance with both laws and relates to actions and activities during the financial year January 1, 2023 to December 31, 2023. References to “we” or “our” are references to Flatirons.

   Flatirons is committed to high standards of professionalism, integrity, and ethical conduct. We do not tolerate any form of slavery, servitude, forced or compulsory labor or human trafficking in any part of our business or our supply chains. We aim to ensure that our supply chains are free from slavery and human trafficking.

2. About Flatirons

   Flatirons Solutions® (www.flatironssolutions.com) provides solutions for aviation and defense content lifecycle management. For more than 30 years, it has helped airlines, MROs, manufacturers, and military forces maintain and operate complex assets more effectively. Its software and service solutions help organizations to deliver the right information, at the right time, to the right people — Turning Content into Knowledge®. Flatirons operates from offices in Asia, Europe, and the United States with its headquarters in Boulder, Colorado. Flatirons includes:

   1. Flatirons Solutions, Inc. – USA
   2. Flatirons Canada Ltd. – Canada
   3. Flatirons SAS – France
   4. Flatirons Solutions Limited – UK
   5. Flatirons Solutions India Private Ltd. – India
   6. Flatirons EMEA A/S – Denmark
   7. Flatirons Danmark A/S – Denmark
   8. Flatirons Norge AS – Norway
   9. Flatirons Sverige AB – Sweden
   10. Flatirons Deutschland GmbH – Germany

   Our supply chain generally includes suppliers of office and IT equipment, recruitment services, office and facilities services, travel services, professional services such as legal and accounting, and subcontractors who may provide equipment, software, or outsourced services related to our business

3. Commitment

   Flatirons acknowledges its responsibilities in relation to tackling modern slavery and human trafficking and commits to complying with the provisions in section 54 of Modern Slavery Act 2015, and FAR 52.222-50 Combatting Trafficking in Persons. Flatirons understands that this requires an ongoing review of both its internal practices in relation to its work force and, additionally, its supply chains.

   Flatirons does not conduct business with any organization, in the United Kingdom or in any other locations, which knowingly supports or is found to involve itself in slavery, servitude, and forced or compulsory labor.

   No employee at Flatirons in the pursuance of the provision of its services is hired by means of slavery or human trafficking. Flatirons strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in any of the locations it operates, and in many cases exceeds those minimum standards in relation to its employees.

4. Policies/ Due Diligence Process
   1. For Employees:

      For all the employees regardless of whether they are existing or newly onboarded, Flatirons has the following policies and procedures in place to be strictly followed by the employees, and any breach of the policies and procedure by an employee results in strict actions.

      1. Global Code of Conduct Policy
      2. Discrimination/Harassment/Sexual Harassment Policy
      3. Global Disciplinary Procedure
      4. Procurement Integrity Policy
      5. Employee Handbooks for all the locations
      6. Combatting Trafficking in Persons and Modern Slavery Policy
   2. For Suppliers:

      As part of our due diligence and risk-based assessment of the suppliers, we have strict policies and procedure in place to follow before conducting business with the suppliers such as:

      1. Purchasing and Outsourcing Policy
      2. Suppliers Selection and Evaluation Processes
      3. Outsourcing Processes
5. Potential Exposure

   Given the nature of our business, Flatirons considers the main exposure to the risk of slavery and human trafficking to be in countries where protection against breaches of human rights may be limited.

   In general, Flatirons considers its exposure to slavery/human trafficking to be relatively limited and there is a very low risk of slavery, servitude, forced or compulsory labor or human trafficking in any part of our business or supply chains. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organization that provides supplies and/or services to it. For example, we address these risks by incorporating due diligence and asking questions relating to modern slavery as part of the process for selecting contractors and obtain modern slavery statements and copies of applicable policies (when they are available).

6. Effectiveness Tracking

   In assessing our effectiveness in combating human trafficking and modern slavery, Flatirons has established Key Performance Indicators (KPIs) and will, where possible, measure our performance against them in the following years. We intend to build upon these KPIs year over year, as we build upon the steps we take in this area.

   1. Conducting and reviewing the number of employees taking online training module regardless of the existing or new employees;
   2. Reviewing the number of suppliers targeted for due diligence processes and accessing them on a risk-based approach

   In addition, our Compliance team is constantly working on improving the process and taking appropriate action to assess and address modern slavery risks as set out in this statement. Flatirons constantly works further to understand suppliers that may raise modern slavery risk, with a focus on ‘high risk’ sectors, industries, products and services, and countries.

7. Training

   To raise awareness and to train the employees and contractors and to help them learn to recognize the risks of modern slavery and human trafficking, Flatirons conducts focused training for all the employees, including in the relevant induction programs and as part of an ongoing compliance training program.

8. Further Steps

   Flatirons will periodically review the effectiveness of the steps that we are taking to ensure the risks of modern slavery and human trafficking in our business, operations, or our supply chains are addressed. We aim to continually monitor and, where necessary, improve any policies, procedures, and systems that we have already implemented.

9. Publication

   This statement and a link to this statement will be posted to our website and internal Wiki and will be accessible to our employees and contractors.

10. Approval

    This statement was approved by the Flatirons Solutions, Inc. Board of Directors on January 3, 2023, who will review and update it annually.

Stéphane Labadie
Director and Chief Executive Officer
Flatirons Solutions, Inc.