Modern Slavery Statement

This statement is made on behalf of Cappfinity Limited and its subsidiaries, which include the following entities: Cappfinity Inc.; Cappfinity Pty Limited; Cappfinity Ireland Ltd, pursuant to section 54(1) of the Modern Slavery Act 2015 (the ‘Act’) and constitutes our business’ slavery, child labour and human trafficking statement for the financial year end 31st December 2023 and outlines the steps we have taken to assess our operations and supply chain and mitigate the risks of slavery and human trafficking. This statement was approved by the board of Cappfinity Limited, and has been approved by our Co-Chief Executive Officers, Alex Linley and Nicky Garcea, on 20th August 2025.

Our business and structure

We are a leading provider offering software and services in skills-based talent acquisition and talent management. We operate in the United Kingdom, Ireland, the United States of America, and Australia and have approximately 200 FTE employees worldwide.

Purpose

Cappfinity wants to be the world leader for measuring and developing potential in Talent Acquisition & Talent Management. Skills-led Talent Acquisition from pre-skilling to seamless onboarding – fast, fair, AI resistant assessment and selection delivering immersive, brand-aligned and insightful experiences. Data-led Talent Management supporting internal mobility and ongoing talent development – engaging, multi-method, scalable and measurable impact at every level across your business. At Cappfinity, we believe in a world where skills and potential create opportunity for all, therefore we take adherence to legislation seriously and strive to always act ethically and with integrity.

Our supply chains

Our supply chain includes cleaning services, couriers, IT hardware and software providers, building and maintenance contractors, IT consultants, recruitment agencies, marketing services, legal and insurance advisers, training providers and criminal and financial screening agents. As a software company, our business model does not carry with it a high level of slavery risk compared to businesses operating in other sectors. Nevertheless, this Statement covers those areas within our business supply chain which we have identified as presenting a potential slavery risk. We continue to focus on these areas to ensure we mitigate any associated risks to a reasonable level. There were no instances of slavery or human trafficking concerns raised to us during the financial year ending 31st December 2023.

Taking action

We are committed to ethical trading principles and to acquiring goods and services without harm to others. We consider our supply chain the main area of potential exposure to forced labour, consequently, over the last number of years we have taken action to mitigate our Modern Slavery exposure in our supply chain. We have implemented a Supplier Management and Due Diligence process which we ensure all of our suppliers, contractors and partners are taken through to ensure we are comfortable working with them. We have updated our supplier onboarding questionnaire which poses questions to potential suppliers on their modern slavery record, and what steps they take to mitigate the risk within their own organisation. Where we consider any new supplier to be within a jurisdiction, industry or sector that is high risk in relation to modern slavery, we will carry out additional due diligence on such suppliers.

Next steps

We implemented enhanced assurance for suppliers with higher risk profiles and intend to record key performance indicators such as the number of suppliers who comply with our aforementioned Supplier Management and Due Diligence process. We also intend to implement appropriate training materials for relevant staff involved in the procurement process, to make them aware of the requirements of the Act.

Our people

As a destination employer for skills-based talent acquisition and management in the UK, the recruitment and engagement of staff is of paramount importance to us and we undertake a thorough pre-employment screening process of all staff. This includes obtaining documented proof of the individual’s right to work in the UK. Our senior leadership team at Cappfinity Limited are responsible for implementing this Statement, which is reviewed at least annually and made available on our website.