Modern Slavery and Human Trafficking Statement

0) Corporate structure and scope

Tanqory PTE. LTD. (Singapore, UEN 202448997H) is the ultimate parent and holding company of the Tanqory group, including its wholly-owned subsidiaries Tanqory Inc. (Delaware, USA) and Tanqory OÜ (Estonia). Tanqory Inc. is the contracting entity and merchant of record for every product and service Tanqory sells to merchants and customers worldwide — Tanqory PTE. LTD. itself does not contract with, bill, or hold a direct customer relationship with any merchant or customer. This document is adopted by Tanqory PTE. LTD. as the group's holding company and applies group-wide, including to Tanqory Inc.'s and Tanqory OÜ's operations, unless a section below states a narrower scope.

1) Purpose

This statement describes the steps that TANQORY PTE. LTD. and its affiliated entities (Tanqory OÜ and Tanqory Inc., together the "Tanqory Group" or "Tanqory") take to identify, prevent, and mitigate the risk of modern slavery, forced labor, child labor, and human trafficking in our own operations and in our supply chain.

It is published with reference to:

• United Kingdom — Modern Slavery Act 2015, Section 54 (transparency in supply chains). The Act applies to commercial organizations carrying on business in the UK with a global annual turnover of £36 million or more. Tanqory does not currently meet this financial threshold and is therefore not a mandatory reporting entity under s.54; this statement is published voluntarily as a pre-listing governance baseline.
• Australia — Modern Slavery Act 2018 (Cth). The Act applies to reporting entities with consolidated annual revenue of AUD 100 million or more that are Australian entities, or that carry on business in Australia. Tanqory does not currently meet this revenue threshold and is therefore not a mandatory reporting entity under the Act; this statement is published voluntarily as a pre-listing governance baseline.
• Canada — Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211), in force 1 January 2024. Applies to entities listed on a Canadian stock exchange, or that meet specified asset, revenue, or employee thresholds, and that produce, sell, distribute, or import goods. Tanqory is not currently listed on a Canadian stock exchange, does not meet the specified thresholds, and its primary offering is a SaaS service rather than goods; it is therefore not a mandatory reporting entity under S-211, and this statement is published voluntarily as a pre-listing governance baseline.
• United States — California Transparency in Supply Chains Act (Cal. Civ. Code §1714.43). Applies to retail sellers and manufacturers doing business in California with annual worldwide gross receipts exceeding USD 100 million. Tanqory Inc. is incorporated in Delaware, does not directly manufacture or sell tangible retail goods, and does not meet the gross-receipts threshold; the Act is therefore not currently applicable, and this statement is published voluntarily as a pre-listing governance baseline.
• United States — Uyghur Forced Labor Prevention Act (UFLPA), as applied to any hardware or physical goods Tanqory imports into the United States.
• European Union — Corporate Sustainability Due Diligence Directive (CSDDD, Directive (EU) 2024/1760), as it is transposed into national law in EU Member States in which Tanqory OÜ or Tanqory operates. Tanqory monitors CSDDD transposition timelines as forward-compatibility planning; this statement does not assert current CSDDD scope coverage.
• International standards — ILO Core Conventions, the UN Guiding Principles on Business and Human Rights (UNGPs), and the OECD Guidelines for Multinational Enterprises, which inform Tanqory's voluntary diligence baseline.

This statement is a governance commitment. It does not constitute a representation that any specific modern-slavery legislation currently applies to Tanqory as a mandatory reporting entity.

2) Reporting entities and reporting basis

This statement covers:

• TANQORY PTE. LTD. — Singapore, UEN 202448997H, registered at 160 Robinson Road, #14-04, Singapore Business Federation Centre, Singapore 068914. Group holding entity, global contracting party, and intellectual-property holder.
• Tanqory OÜ — Estonia, registration 17353783, registered at Ahtri tn 12, 10151 Tallinn, Estonia. EU operations and EU representative for DSA, AI Act, and GDPR purposes.
• Tanqory Inc. — Delaware, USA, Delaware State File Number 10374166, EIN 37-2212745, with registered agent address at 16192 Coastal Highway, Lewes, Delaware 19958. United States operations and US contracting party.

As of the effective date, Tanqory does not currently meet the mandatory financial or operational thresholds that would make reporting compulsory in any of the jurisdictions referenced in Section 1, and is not currently a mandatory reporting entity in any of them. Tanqory publishes this statement on a voluntary, pre-listing governance basis so that the controls described here are documented and auditable in advance of any future threshold being crossed or any future public listing.

If and when Tanqory meets a mandatory reporting threshold in any jurisdiction, this statement will be re-issued under the formal approval, signature, and publication requirements of that jurisdiction's statute.

3) Organization, operations, and supply chain

Tanqory is a software-as-a-service ("SaaS") platform for building and operating online stores. Tanqory does not own or operate factories, warehouses, agricultural sites, fisheries, or extractive operations.

Workforce. Tanqory's personnel consist of employees, contractors, and consultants engaged by the three entities described above. All personnel perform professional services (software engineering, product, design, sales, marketing, operations, legal, and finance). Tanqory does not engage low-wage manual labor, seasonal labor, or labor recruited through cross-border brokers.

Supply chain. Tanqory's supply chain is dominated by digital service providers (cloud infrastructure, content delivery, observability, communications, payments, identity, and developer tooling). The current set of material subprocessors is published in Tanqory's Subprocessor List and updated as the list changes.

Beyond cloud and SaaS subprocessors, Tanqory procures:

• Professional services (legal, accounting, audit, tax, corporate secretarial, registered-agent services).
• Office, hardware, and end-user equipment for personnel (laptops, peripherals, mobile devices).
• Marketing, content, translation, and design services.

Tanqory does not currently source goods through high-risk industry sectors typically associated with modern-slavery exposure (textile and apparel manufacturing, agriculture, fishing, mining, construction, electronics manufacturing operations). Tanqory's exposure to such sectors is indirect, through the upstream supply chains of its hardware vendors and cloud providers.

4) Policies relevant to modern slavery

This statement is supported by the following internal policies, which all personnel and, where applicable, business partners are required to follow:

• Code of Business Conduct — prohibits forced and child labor, discrimination, harassment, and retaliation; requires escalation of concerns through the Speak Up channel.
• Corporate Social Responsibility (CSR/ESG) Policy — sets the human-rights and labor-standards baseline (UDHR, ILO Core Conventions) and the supplier-diligence baseline.
• Anti-Harassment, Discrimination, and Equal Employment Opportunity Policy — covers workplace conduct standards across all three entities.
• Whistleblower Policy — provides a confidential, anti-retaliation channel for reporting any concern, including suspected modern slavery, forced labor, or trafficking.
• Acceptable Use Policy — prohibits use of the Tanqory platform to facilitate human trafficking, forced labor, or exploitation.
• Vendor Code of Conduct — sets the labor, human-rights, anti-corruption, and data-protection standards that material vendors are expected to meet. The Company is establishing a standalone Vendor Code of Conduct; pending its formal adoption, equivalent vendor obligations are flowed down through contract clauses and the Code of Business Conduct.

5) Due diligence on subprocessors and material vendors

Tanqory's due-diligence process for new material subprocessors and vendors covers:

1. Identification. Categorization of the vendor by risk (data-processing scope, infrastructure criticality, geographic footprint, sector).
2. Verification. Confirmation of legal existence, beneficial ownership where reasonably available, sanctions screening (UN, EU, OFAC, UK, Singapore), and adverse-media screening for high-risk relationships.
3. Contractual flow-down. Vendor contracts include, where commercially achievable, representations and warranties that the vendor (a) does not use forced, bonded, indentured, or child labor; (b) complies with applicable labor and human-rights laws; and (c) flows equivalent obligations down to its own material subcontractors.
4. Ongoing review. Material subprocessors are listed on Tanqory's public Subprocessor List. Material changes are notified in accordance with Tanqory's Data Processing Addendum.

Tanqory has not, as of the effective date, conducted or commissioned on-site, SMETA, or equivalent third-party labor audits of any subprocessor or vendor. The Company will commission such audits on a risk-based basis where the nature of a vendor relationship warrants them.

6) Risk areas

Tanqory identifies the following residual modern-slavery risk areas relevant to a SaaS organization of its profile:

• Cloud and data-center labor. Construction, fit-out, security, and facilities labor at hyperscale data centers operated by Tanqory's cloud subprocessors. Tanqory relies on these subprocessors' own labor and human-rights programs and on contractual representations.
• Content moderation and trust-and-safety outsourcing. To the extent Tanqory engages third-party trust-and-safety vendors, those workforces can face well-documented psychological-safety and labor-conditions concerns. Tanqory does not currently engage a dedicated third-party content-moderation vendor; should it do so, the Company will apply working-conditions controls and contractual safeguards appropriate to the risk.
• Hardware supply chains. End-user laptops, peripherals, and mobile devices procured for personnel originate from global electronics supply chains that are recognized as elevated-risk for forced labor (notably in connection with UFLPA-listed regions). Tanqory's mitigations rely on procuring from established OEMs with published responsible-sourcing programs.
• Professional services. Cleaning, catering, and facilities services associated with any office Tanqory may occupy. Tanqory currently has no separately leased office space outside its registered addresses; risk is therefore presently de minimis.
• Platform misuse risk. The Tanqory platform itself could in principle be used by a merchant to advertise or facilitate trafficking. The Acceptable Use Policy prohibits such use; suspected violations are reported through the abuse channel and may be reported to law enforcement as legally required.

7) Effectiveness measurement

Tanqory's controls are assessed against the following indicators:

• Number of suspected modern-slavery or forced-labor concerns reported through the Speak Up channel, by source and by outcome.
• Number of new material vendors onboarded during the period, and the percentage subjected to labor-standards diligence.
• Number of platform Acceptable Use Policy reports relating to trafficking or exploitation, and disposition.
• Completion rate of mandatory training (see Section 8).

The Company is establishing baseline values for each indicator and will report on them to the Board or its Audit Committee periodically, on a risk-based basis and no less than annually.

8) Training and awareness

All personnel are required to complete the Code of Business Conduct training, which includes a module covering forced labor, child labor, and trafficking red flags. Personnel in procurement, vendor management, trust and safety, and legal receive additional role-specific training.

The Company is establishing modern-slavery awareness training delivered on a periodic, risk-based basis, including refresher training, and will set and track a completion-rate target for all in-scope personnel.

9) Remediation

Where Tanqory identifies or has credible reason to suspect modern slavery, forced labor, child labor, or human trafficking in its own operations or in a material vendor relationship, Tanqory will:

1. Preserve evidence and document the concern.
2. Where the concern relates to an individual at risk, prioritize the safety and well-being of the affected person, in consultation with qualified specialist organizations where appropriate.
3. Investigate through Legal and the Speak Up process, with conflicts managed under the Whistleblower Policy.
4. Where a vendor is implicated, require a corrective-action plan with defined milestones; suspend onboarding or pause work where the concern is material and unresolved; and terminate the relationship where remediation is refused or fails.
5. Report to law enforcement and regulators where required by applicable law.
6. Provide or support access to remedy for affected persons consistent with UN Guiding Principle 22, taking into account our leverage and proximity to the harm.

10) Approval

This statement is approved by the Board of Directors of TANQORY PTE. LTD., on behalf of itself and its affiliated entities Tanqory OÜ and Tanqory Inc. This statement will be reviewed and re-approved annually by the Board, and the corresponding board resolution will be recorded in the Company's minute book.

11) Signature

Signed for and on behalf of the Board of Directors of TANQORY PTE. LTD. by the director designated by the Board, on the date of the Board's approval recorded in Section 10.

12) Annual republication

Tanqory will review this statement at least annually and republish it where Tanqory's risk profile, supply chain, organizational structure, or applicable legal obligations have materially changed. Each republished version will carry a new version number, effective date, and last-updated date, and where required by statute, a fresh board approval and signature.

13) Adoption note

This is the first version of the Tanqory Modern Slavery and Human Trafficking Statement. It is issued voluntarily as a pre-listing governance baseline. Nothing in this statement should be read as an admission that any specific modern-slavery statute currently applies to Tanqory on a mandatory basis, nor as a waiver of any defense available under such statutes.

Version History