GEIG – MODERN SLAVERY & HUMAN TRAFFICKING STATEMENT (v1.2)
Effective: 1 August 2025 • Publication hub: GeiG Legal Hub

1.0 Purpose and Scope

1.1 This statement sets out GeiG’s actions to prevent modern slavery and human trafficking in our business and supply chains in line with section 54 of the UK Modern Slavery Act 2015.
1.2 GeiG’s global turnover is expected to meet or exceed the statutory threshold. This is our first statement since GeiG launched in August 2025. We will publish updates at least annually and when material changes occur.

2.0 Our organisation and legal reporting entity

2.1 GeiG is a trading name of Computerko Limited (Company No. 11125670) which operates the GeiG business and publishes this statement as the reporting entity. Operational support is provided by Computerko.
2.2 Activities in scope: design, procurement and sale of computing hardware and accessories, cloud services, warranty and after-sales support, logistics and marketing.
2.3 Geography: operations in the United Kingdom with sourcing and manufacturing relationships in Asia and elsewhere. This Statement covers GeiG and any subsidiaries under our control.

3.0 Our policies and standards

3.1 Supplier Code of Conduct mandatory for all suppliers; it prohibits forced, bonded and child labour, requires lawful wages and hours, and requires safe working conditions. The Code must be flowed down the supply chain.
3.2 Related policies: Whistleblowing, Anti-Bribery & Corruption, Recruitment & Agency Workers, Ethical Procurement and Supply-Chain Due-Diligence.
3.3 Contract clauses all supplier contracts include modern slavery representations and warranties, audit rights, remediation obligations and recruiter-fee clauses requiring employer-pays remediation where recruitment fees are identified.
3.4 Standards alignment supplier expectations map to ILO Core Conventions and the Ethical Trading Initiative (ETI) Base Code.

4.0 Risk landscape and prioritisation

4.1 Key higher-risk categories for our sector: electronic components and minerals (including conflict minerals), assembly and manufacturing, warehousing and logistics, and contingent/agency labour.
4.2 We use a risk-based methodology that incorporates country risk, commodity risk, labour model (e.g., agency labour), supplier size and audit history to prioritise due diligence and controls.

5.0 Due diligence and controls

5.1 Onboarding all new suppliers involves a due diligence questionnaire, sanctions/ESG screening, verification of corporate credentials, and acceptance of our Supplier Code and contractual clauses.
5.2 Independent audits Higher-risk suppliers are required to supply independent third-party social audit reports (e.g., SEDEX/SMETA, RBA or equivalent) or to accept GeiG-commissioned audits. Audit frequency: at least annually for high-risk suppliers and every 24 months for medium-risk.
5.3 Monitoring scheduled and trigger-based reviews, including unannounced site visits where credible risk indicators exist (rapid workforce change, grievances, refusal to provide documentation). Worker interviews and direct observation are core audit features.
5.4 Recruitment & agency workers suppliers must demonstrate ethical recruitment practices; agency workers must be engaged via accredited labour providers; any recruitment fees identified will be repaid to workers under an employer-pays remediation model.
5.5 Data & records due diligence and audit records are retained for at least six years.

6.0 Remediation and escalation

6.1 Where non-conformance is identified, we require a Corrective Action Plan (CAP) with time-bound milestones and independent verification of closure. CAPs for high-risk findings normally require verification within 90 days.
6.2 If remediation fails or harm is substantiated, GeiG will suspend new orders, place the supplier on hold or terminate contracts, balancing the need to protect workers during transition. Controlled exit plans will be used where an abrupt termination would harm workers.
6.3 Victim-centred remediation practical remedies prioritise the worker: repayment of recruitment fees, continuation of pay during transition where practicable, access to medical and legal support where needed, and secure relocation or safe repatriation.
6.4 Serious incidents or suspected criminality will be reported to competent authorities and relevant law enforcement agencies, and GeiG will cooperate fully.

7.0 Worker voice, grievance channels and non-retaliation

7.1 We operate multiple worker-facing grievance channels: (a) web chat and email (support@geig.co.uk) with anonymity options; (b) supplier-managed confidential reporting in local languages; and (c) independent third-party hotlines for higher-risk sites where appropriate.
7.2 Suppliers must inform workers of these channels in their language and guarantee non-retaliation. Evidence of worker-voice mechanisms and uptake is reviewed in audits.

8.0 Training and capacity building

8.1 Internal training procurement, HR, operations and leadership receive modern-slavery training every six months, covering red flags, interviewing, grievance handling and escalation. Completion is monitored and reported to senior management.
8.2 Supplier training Higher-risk suppliers must provide annual training to supervisors and HR on forced-labour indicators, grievance handling and remediation; suppliers must provide evidence of training.

9.0 Effectiveness, KPIs and transparency

9.1 We will publish baseline values and progress in the next annual statement. Key performance indicators include:

• ≥95% of active suppliers signed to Supplier Code of Conduct;
• ≥90% of higher-risk suppliers audited by an independent third party in the audit cycle;
• ≥85% of CAPs closed on time (median closure ≤ 90 days);
• 100% training completion for in-scope staff within the 6-month cycle;
• median time to first response to grievances ≤ 5 business days; ≥95% grievance resolution within 30 days.
  9.2 Responsibility for KPI delivery and reporting sits with Procurement and the Supply-Chain Due-Diligence function; aggregated KPI performance will be reported annually to the Board.

10.0 Governance and accountability

10.1 Operational responsibility: Supply-Chain Due-Diligence and Procurement teams. Policy oversight and effectiveness: Director and the Board.
10.2 Significant incidents, material risks or failure of remediation are escalated to the Director and the Board for decision on suspension, termination or public reporting.
10.3 Board review: the Board will annually review modern-slavery risk, remediation effectiveness and resource needs.

11.0 Next steps (FY 2025/26 roadmap)

11.1 Complete baseline risk mapping of tier-1 suppliers and extend mapping to critical tier-2 suppliers where feasible.
11.2 Publish the Supplier Code of Conduct and our due diligence criteria on the Legal Hub.
11.3 Implement worker-voice mechanisms (local language posters/QR, hotline access) at higher-risk sites.
11.4 Integrate modern-slavery checks into contract renewals and purchase order gating, and roll out supplier capacity building for higher-risk partners.

12.0 Publication and accessibility

12.1 Period covered: 1 August 2025 – 31 July 2026. Updates will be published within six months of period end.
12.2 This statement is published on the GeiG Legal Hub, and a prominent link appears on GeiG.co.uk. The statement is available in large-print/plain-text on request.

13.0 Contacts and remedies for workers

13.1 Public contact for concerns: support@geig.co.uk and 24/7 web chat on GeiG.co.uk. Anonymous reports are accepted and will be treated confidentially.
13.2 Postal: GeiG, 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom.

14.0 Approval and sign-off

14.1 This statement was approved by the Board of Directors of Computerko Limited (trading as GeiG) on 1 August 2025.
14.2 Signed by: Keith Charles, Director (on behalf of the Board).
14.3 Date of signature: 1 August 2025.