Modern Slavery and Anti-Human-Trafficking Statement

Statutory Basis

This Statement is published in compliance with:

• California Transparency in Supply Chains Act, Cal. Civ. Code § 1714.43 (applicable to retailers and manufacturers doing business in California with annual worldwide gross receipts exceeding $100 million);
• UK Modern Slavery Act 2015, § 54 (applicable to commercial organizations carrying on a business in the United Kingdom with an annual turnover of £36 million or more);
• Australia Modern Slavery Act 2018 (applicable to entities with consolidated annual revenue of at least AUD $100 million);
• Canada Fighting Against Forced Labour and Child Labour in Supply Chains Act (S.C. 2023, c. 9).

This Statement covers the fiscal year ending December 31, 2025 and is reviewed and reissued annually.

Our Business and Supply Chain

Upmos Inc. is a US-based online marketplace headquartered in Houston, Texas, that connects independent sellers and consumers. We do not directly manufacture, import, or warehouse the products sold on our marketplace; those activities are performed by our independent vendors. Our supply chain therefore primarily consists of:

• Independent third-party vendors and their upstream suppliers;
• Logistics and fulfillment providers (including 3PL warehouses and last-mile carriers);
• Technology vendors (cloud-hosting, payments, customer-support tooling).

Policies in Place

We maintain the following policies that address modern slavery and human-trafficking risk:

• This Modern Slavery Statement;
• Acceptable Use Policy, prohibiting use of the marketplace for any activity that contributes to forced labor, debt bondage, or human trafficking;
• Marketplace Participation Agreement, requiring vendors to comply with all applicable employment, immigration, and human-rights laws;
• Vendor Code of Conduct (integrated into the MPA);
• Prohibited & Restricted Products Policy, prohibiting the sale of products produced wholly or in part by slave or trafficked labor;
• Whistleblower Policy (available at /whistleblower-policy/).

Vendor Due Diligence

Every vendor seeking to participate on the Upmos marketplace must:

1. Complete our Seller Onboarding & Verification process, including ID.me identity verification, Plaid bank verification, and OFAC sanctions screening;
2. Affirm in the MPA that the vendor and its suppliers do not engage in or knowingly source from any entity that engages in forced labor, child labor, debt bondage, or human trafficking;
3. Agree to provide on demand a Conflict Minerals attestation (for relevant categories), country-of-origin documentation, and supply-chain mapping where reasonably available.

Risk Assessment

We assess slavery and trafficking risk along three primary dimensions:

• Geographic risk — sourcing from countries identified as high-risk in the U.S. State Department’s Trafficking in Persons (“TIP”) Report or the Walk Free Foundation’s Global Slavery Index;
• Sector risk — categories with documented forced-labor exposure (electronics manufacturing, textiles, agricultural products, seafood);
• Vendor-specific risk — based on adverse-media monitoring, government watch lists, and prior reports.

Vendors flagged as elevated risk are subject to enhanced due diligence, supplier audits, and may be required to participate in a supply-chain transparency program.

Audits

We reserve the right to audit any vendor and their supply chain for compliance with this Statement. Audits may be conducted directly, through a contracted third-party auditor (such as Verité, Sedex, or Bureau Veritas), or by requiring the vendor to submit a third-party Social Compliance Audit (e.g., SMETA 4-Pillar, SA8000, BSCI).

Training

All Upmos employees who participate in vendor onboarding, trust and safety, or category management receive annual training on:

• Identifying signs of forced labor and human trafficking;
• Escalation procedures when red flags are identified;
• The legal obligations under each of the statutes above;
• Whistleblower protections.

Internal Accountability

Compliance with this Statement is overseen by the Upmos Trust & Safety Council, which reports quarterly to the Board of Directors. Failure by an Upmos employee to comply with this Statement is grounds for discipline up to and including termination. Failure by a vendor is grounds for suspension or termination of selling privileges, escrow holds, and reporting to applicable government authorities.

Reporting Concerns

Concerns about possible slavery or human trafficking in the Upmos supply chain may be reported confidentially:

• Via the Upmos Whistleblower Hotline at +1 (713) 555-0188 (anonymous);
• By email to ethics@upmos.com;
• To the U.S. National Human Trafficking Hotline at 1-888-373-7888 or text “HELP” to 233733;
• To the Modern Slavery Helpline (UK) at 08000 121 700.

Approval and Annual Review

This Statement was approved by the Board of Directors of Upmos Inc. on the “Last Revised” date and will be reviewed at least annually. The current and prior versions of this Statement are archived at /transparency-report/.

Contact

Email: ethics@upmos.com · legal@upmos.com

How Can You Contact Us About This Policy?

If you have any further questions or comments or wish to report any problematic Content or Contribution, you may contact us by:

General Contact

• Phone: 1(855)637-2433 (Mon–Fri, 7 AM–8 PM CT)
• General Support: support@upmos.com
• Report Issue: upmos.com/report
• Send Feedback: upmos.com/feedback

Department Directory

Mailing Address

Upmos Inc.
9896 Bissonnet St
Houston, TX 77036
United States