For the financial year ending 30 September 2025
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 by Aptos Solutions UK Limited (registered company number 10238826), whose registered office is at 7th Floor, 50 Broadway, London SW1H 0DB, UK ("Aptos UK"), and covers the financial year which ended on 30 September 2025. Aptos Solutions UK Limited is part of the Aptos group of companies, headquartered in Alpharetta, Georgia, USA ("Aptos/Group/we/our/us"). This statement sets out the steps taken during the financial year ended 30 September 2025 to help prevent modern slavery and human trafficking in our business and supply chains.
The statement describes the steps taken during the reporting period to prevent modern slavery and human trafficking in the Group’s business and supply chains.
Modern slavery is a crime and a violation of fundamental human rights. It includes slavery, servitude, forced and compulsory labour, and human trafficking. Aptos is committed to acting ethically and with integrity in its business dealings and relationships and to implementing and enforcing effective systems and controls designed to reduce the risk of modern slavery in its business and supply chains.
Aptos is a global retail technology company that specialises in unified commerce solutions for retailers. With more than four decades of experience in retail technology, Aptos provides modern, cloud‑native and on‑premise software that supports key retail processes including point of sale, order management, merchandising, analytics and customer relationship management. Aptos’ solutions are used by many retail brands worldwide to help them deliver consistent customer experiences across channels, improve operational efficiency and support sustained revenue growth.
In the UK, Aptos UK employs around 70 people in predominantly office‑based, professional roles across functions such as sales, professional services, customer support and corporate functions. The business does not operate manufacturing facilities in the UK and its own operational model is primarily technology and services based.
Aptos procures technology hardware, software applications, cloud and other technology services, consultancy and other business services from suppliers located mainly in the North America, UK, Europe and India.
Given the nature of our business, we consider the risk of modern slavery in our directly employed UK workforce to be relatively low. However, we recognise that modern slavery risks can arise in global supply chains, particularly in areas involving hardware manufacturing, outsourced or offshore services, labour-intensive services and multi-tier subcontracting arrangements. We therefore seek to maintain appropriate oversight of our supplier relationships and to take a risk-based approach to identifying and addressing potential areas of exposure.
Aptos seeks to maintain a culture of lawful, ethical and respectful conduct throughout its business. Our Code of Conduct and Business Ethics sets out the standards of behaviour expected of employees and contractors and supports our commitment to compliance, integrity and respect for others. We expect suppliers and business partners to operate fair and ethical workplaces, to treat workers with dignity and respect and not to tolerate any form of exploitation in their business or supply chains.
We also maintain whistleblowing arrangements through which employees and others can raise concerns regarding suspected misconduct, including serious concerns relating to breaches of law, policy or our Code of Conduct and Business Ethics. Reports can be made anonymously where the reporting individual chooses to do so, and our whistleblowing approach is expressly anti-retaliation. Concerns raised are taken seriously and are investigated promptly and appropriately.
Responsibility for this statement and the oversight of our approach to modern slavery sits with the senior management of Aptos, supported by relevant legal, human resources and business stakeholders within the wider Aptos group.
Aptos applies a proportionate and risk-based approach to modern slavery due diligence. In the context of supplier onboarding, renewal and ongoing relationship management, we consider factors such as the nature of the products and services supplied, the jurisdictions in which suppliers operate and any other indicators that may suggest elevated labour-rights risk. This helps us focus our attention on supplier categories and geographies where the risk of modern slavery may be comparatively higher.
Aptos expects suppliers and partners not to tolerate exploitation in their business or any part of their supply chain. We seek to work with suppliers that adopt standards consistent with our own expectations of lawful and ethical conduct. As part of the continued development of our vendor screening programme, we intend to keep our supplier onboarding and contractual documentation under review so that our modern slavery expectations are addressed clearly and consistently, particularly for suppliers assessed as higher risk.
Where appropriate, Aptos may request additional information from suppliers in relation to labour standards, governance, supply chain controls or relevant policies. Where concerns are identified, these may be escalated internally for further review and may result in additional due diligence, requests for remedial action or reconsideration of the supplier relationship, depending on the nature and seriousness of the issue.
Where appropriate, we apply enhanced due diligence to higher-risk supplier arrangements, including offshore development centres in India and similar jurisdictions. This may include targeted questions on workforce composition, recruitment practices, use of subcontractors, working conditions and the availability of confidential grievance or whistleblowing mechanisms for workers involved in delivering services to Aptos.
Modern slavery risk is not uniform across all organisations, sectors or geographies. In assessing our own risk profile, we have regard to the nature of our business model, workforce profile and supply chain footprint. While our own operations are predominantly office-based and professional in nature, we recognise that certain parts of our wider supply chain may present greater inherent risk, particularly where services or goods are sourced through complex international supply chains.
We are committed to reviewing and improving the effectiveness of our approach over time. Relevant indicators may include completion of employee training, the extent of due diligence undertaken for higher-risk suppliers and the number and nature of concerns raised through our reporting channels. During the reporting period, we did not identify any instances of modern slavery or human trafficking in our UK operations. However, we recognise that the absence of reported cases does not eliminate the need for continued vigilance, assessment and improvement.
All Aptos employees and contractors are required to undertake mandatory annual training to ensure compliance with our Code of Conduct and Business Ethics. This training covers ways to identify ethical issues and potential breaches, including harassment and discrimination, and highlights the steps staff can take if they are concerned about conduct that may breach the Code. Aptos staff also receive information on whistleblowing and on how to raise serious concerns through available reporting channels, including anonymous channels where preferred.
We consider training and awareness to be important elements of an effective approach to preventing modern slavery. We therefore intend to continue reviewing whether additional targeted guidance should be provided for employees in roles such as Legal, vendor management and human resources, where there may be greater opportunity to identify modern slavery risks in practice.
Aptos is committed to continuously improving its practices to support efforts to tackle modern slavery within its business and the wider business community. During the next reporting period, we intend to continue developing our risk-based supplier due diligence processes, review our standard supplier documentation and onboarding materials, enhance internal tracking of relevant training and supplier due diligence activity, and keep our risk assessment and this statement under annual review.
This Modern Slavery Statement has been approved by the director of Aptos Solutions UK Limited as of 30 June 2026.
Zaki Hassan
Director of Aptos Solutions UK Limited