LEGAL · MODERN SLAVERY STATEMENT

Modern slavery and human trafficking.

This statement sets out the steps CN Solar Labs GK and the companies in its group have taken to identify and prevent slavery, servitude, forced or compulsory labour, and human trafficking in our own operations and in our supply chains. It covers the financial year ending 31 March 2026.

01

Our structure and operations

CN Solar Labs GK is a godo kaisha (合同会社) incorporated in Japan, with its office at Azabudai Hills Mori JP Tower, 50F, Tokyo. It is the parent of a founder-controlled group of technology companies working across data, infrastructure, distribution, and capital. Every company in the group was founded in-house; none was acquired, which means we have never inherited a supply chain we did not choose.

The group is small and directly employed. We do not operate manufacturing plants, farms, mines, or logistics warehouses, and we do not use labour agencies, gangmasters, or outsourced production of any kind. Our work is done by people we employ ourselves, under written contracts, paid directly by us.

02

Our supply chains, and where the risk actually sits

The honest assessment is that our direct risk is low and our indirect risk is not zero, and it is worth being specific about which is which rather than declaring the whole thing low-risk and moving on.

CLOUD AND SOFTWARE · LOW RISK

Compute, storage, networking, and software licences bought from established corporate suppliers. Labour risk in the direct relationship is low; it sits further down, in the construction and operation of data centres, where we have limited visibility.

HARDWARE AND ELECTRONICS · HIGHEST RISK

Laptops, servers, displays, and networking equipment. Consumer and enterprise electronics have documented risks of forced labour in mineral extraction and in component assembly, several tiers below the vendor we actually buy from. This is the part of our chain we treat as highest risk and it is where our diligence is focused.

FACILITIES AND BUILDING SERVICES · MEDIUM RISK

Cleaning, security, catering, maintenance, and fit-out at the buildings we occupy. These services are typically contracted by the building operator rather than by us, and low-paid outsourced facilities labour is a recognised risk category.

PROFESSIONAL SERVICES · LOW RISK

Legal, accounting, recruitment, insurance, and similar. Regulated professions, directly contracted.

TRAVEL AND EVENTS · LOW RISK

Airlines, hotels, and venues, booked directly. Hospitality carries some labour risk in its own supply chain.

We buy laptops from a reseller and compute from a cloud. Neither of those is where the risk lives. It lives four tiers below both, and pretending otherwise is the failure mode of statements like this one.

03

Our policies

The following are group policy and apply to every company in it. Several of them are published in full on the careers pages because they are also how we recruit.

  • Zero tolerance. We will not knowingly engage with any supplier, partner, or intermediary involved in slavery, forced labour, child labour, or human trafficking, and we will end a relationship where we find it and remediation is refused.
  • No worker-paid fees. No person may ever be charged a fee, deposit, or debt in order to be recruited by us or to work for us, at any stage, by us or by anyone acting for us. Debt bondage begins with a recruitment fee.
  • Direct employment. We employ our people directly on written contracts, in their own name, with pay made to an account in their own name. No unpaid internships, no unpaid work trials, and paid time for any assessment that runs long.
  • A published pay floor. Everyone in the group, including the earliest-career roles, is paid on the same published floor. Underpayment is the ground that exploitation grows in, and a floor makes it visible.
  • Documents stay with their owner. We never retain a person's passport, residence card, or identity documents. Right-to-work checks are done by sight and the documents are returned immediately.
  • Freedom to leave. Contractual notice periods are reasonable, no one is tied by debt or by a document we hold, and anyone may resign.
  • Speaking up without penalty. Anyone in the group, or anyone in our supply chain, may raise a concern about labour conditions directly with management. We will not retaliate, and we will protect the identity of the person who raised it as far as we are able.

04

Due diligence

Our diligence is proportionate to a group of our size, which means it is done by people rather than by a compliance system, and we would rather describe it accurately than dress it up.

  • We check new suppliers of hardware and facilities services for a published modern slavery or human-rights position, and prefer suppliers who have one and who publish audit findings rather than assurances.
  • We buy electronics from established vendors and resellers with published responsible-sourcing programmes, and we keep equipment in service for as long as it is useful. Buying less, and later, is the single largest lever a company of our size actually has.
  • Material supplier contracts include a right to terminate for a breach of our zero-tolerance policy, and a requirement to pass equivalent obligations down the chain.
  • Where facilities services are contracted by a landlord or building operator rather than by us, we ask for their policy and treat a refusal to provide one as a factor in the tenancy decision.
  • We investigate any credible concern raised with us, whether it concerns our own operations or a supplier's, and we record what we found and what we did about it.

05

Training and awareness

Everyone in the group is briefed on this statement, on the indicators of forced labour and trafficking, and on how to raise a concern. People who make purchasing decisions or who take part in hiring receive additional briefing on recruitment fees, document retention, and supplier selection, because those are the three points at which a small company can actually cause harm.

06

How we measure whether this is working

We do not have audited supply-chain metrics and we are not going to invent any. What we track today is deliberately modest, and we would rather report four true numbers than twenty assembled ones.

  • Concerns raised, and what happened to each one. In the period covered by this statement: none raised.
  • Instances of slavery, forced labour, or trafficking identified in our operations or supply chain. In the period covered by this statement: none identified.
  • Proportion of material suppliers with a published human-rights or modern slavery position, reviewed at onboarding and annually.
  • Confirmation, each year, that no person was charged a fee to be recruited by us and that no identity document was retained by us.

07

Reporting a concern

If you believe anyone connected with this group, at any tier of our supply chain, is being subjected to forced labour, trafficking, or exploitation, tell us. Write to hello@cnsolarlabs.com or to the postal address below. You do not need evidence and you do not need to be certain. We would rather look into ten concerns that come to nothing than miss one.

If someone is in immediate danger, contact the emergency services in that country first. We are not a substitute for them.

08

Approval

This statement is made in respect of the financial year ending 31 March 2026 and is published on a voluntary basis in the spirit of section 54 of the UK Modern Slavery Act 2015 and of Japan’s Guidelines on Respecting Human Rights in Responsible Supply Chains. It has been approved by the management of CN Solar Labs GK and will be reviewed and republished annually.

APPROVED FOR AND ON BEHALF OF

CN Solar Labs GK

Representative Member · 9 August 2026

Azabudai Hills Mori JP Tower, 50F

1-3-1 Azabudai, Minato-ku

Tokyo 106-0041

Japan

LAST UPDATED 9 AUGUST 2026