Legal

Legal

Introduction from the Directors

The divergent Group is committed to preventing slavery and human trafficking in every part of its business and its supply chains. This statement is made with reference to section 54 of the Modern Slavery Act 2015 and sets out the steps we have taken during the current financial year to identify and address that risk.

Our structure

divergent is a technology group building and operating software products for businesses and consumers: messaging, bookings, electric vehicle charging, eSIM connectivity and related services. This statement covers the divergent Group and its member companies, including divergent UK Operations Ltd, UAB divergent EU Operations and SquareUp Charging Limited. We operate from the United Kingdom and Lithuania, and our workforce is small, salaried, and employed directly or engaged as professional contractors.

Our policies on slavery and human trafficking

We do not use forced, bonded or child labour and will not knowingly work with any supplier or partner that does. Our hiring follows a documented process with identity and right-to-work checks for every hire, and every employee and contractor is paid directly at or above the applicable minimum. Our Acceptable Use Policy prohibits use of our Services in connection with human trafficking or exploitation, and we act on reports of such use.

Due diligence

Our supply chains are short. They consist mainly of cloud infrastructure, connectivity and telecommunications providers, software and professional services, payment processors, and, for Inflo, electric vehicle charging hardware manufactured by third parties and installed by our customers. When onboarding a supplier in a higher-risk category we check for a published modern slavery or ethical sourcing policy and, where none exists, ask for one. We reserve the right to end any supplier relationship where a concern is identified and not resolved.

Risk and compliance

As a service-based technology business purchasing mainly from established operators and cloud providers, we assess the risk of slavery or human trafficking in our operations and direct supply chain as low. The area of greatest risk is hardware manufacturing in the charging supply chain, where we rely on manufacturers with their own published statements and monitor them through the onboarding checks above.

Effectiveness

We measure our performance against this statement by:

Training

Staff responsible for procurement and hiring are briefed on the indicators of modern slavery, how to raise a concern, and what happens when one is raised. This briefing is refreshed annually.

Reporting

Anyone who believes that slavery or human trafficking is taking place within our business or supply chains can report it to . Reports are handled confidentially.

Further actions and sign-off

Over the next financial year we will complete a review of our higher-risk suppliers against the checks above and record the outcome. This statement was approved by the directors of divergent UK Operations Ltd in September 2026 and will be reviewed annually.