Modern Slavery Statement

Last updated and effective: June 19, 2025

INTRODUCTION

This Modern Slavery Statement (“Statement”) is made by StackAdapt UK Limited (“StackAdapt UK”, “us”, “our”, or “we”), a private limited company incorporated in England and Wales, and wholly owned by StackAdapt Inc. (“StackAdapt”, or “Parent”), in compliance with section 54 of the Modern Slavery Act 2015 (the “Act”), and describes the actions taken by StackAdapt UK during the financial year ended December 31, 2024, to prevent modern slavery; including slavery, forced labour, debt bondage, child labour, domestic servitude, and human trafficking (collectively “Modern Slavery”) within our operations and supply chains.

OUR BUSINESS AND SUPPLY CHAIN

Structure
StackAdapt UK is part of the StackAdapt group. Established in 2014, StackAdapt is a leading multi-channel programmatic advertising platform that provides programmatic advertising and marketing services to advertisers and advertising agencies who use these services to buy, track, and manage their digital media to deliver native, display, video, connected TV, audio, in-game, and digital out-of-home advertisements (“StackAdapt Platform”).

StackAdapt is a global company that operates under a fully remote model. Subsidiaries within the StackAdapt group, including StackAdapt UK, generally adhere to policies and processes established by StackAdapt, and share centralized procurement, finance, legal, and other company resources.

Supply Chains
Primarily, our supply chain includes the sourcing of data and third-party services to support the infrastructure and availability of the StackAdapt Platform, and the publishing and distribution of online content and communications.

In addition, we source products and third-party services to support our administrative and operational needs, such as:

information technology network/equipment, accessories, software, and consulting
services;
furniture, office equipment, and food and beverage services
financial services, including banking services and insurance;
media, marketing, events, and travel and hospitality;
legal advice, audit, and payroll services;
providers of private healthcare, employee benefits, and other associated services

OUR COMMITMENT

We understand the importance of and are committed to assessing and mitigating modern slavery risks within our operations and supply chains.

Our Policies and Training
StackAdapt has policies and procedures in place that seek to ensure that all employees, contractors, and consultants within its group, including StackAdapt UK, are safe, healthy, and working of their own free will. We maintain a Health and Safety Policy that establishes measurable health and safety objectives. We also maintain an internal Ethics Hotline Policy, under which employees are encouraged to report in a confidential manner, or if desired, anonymously, concerns, allegations, or violations of policies, rules, or regulations.

Upon hire or material update, our employees, contractors, and consultants are provided materials and training that detail our policies, core values, and internal channels to seek assistance, as needed.

Hiring Due Diligence and Risk Assessment
In our hiring process, we use a standardized, procedural approach to ensure our compliance with the Act. We also monitor and adhere to local labour laws to recruit and employ our employees, contractors, and consultants.

Contractual Provisions and Due Diligence
In our procurement process, we utilize a risk-based approach to ensure we are minimizing the risk of modern slavery within our supply chain. We are constantly evaluating and updating our due diligence practices with respect to vendor procurement; presently, our approach may include measures, such as (i) a detailed security review; (ii) contractual warranties from the vendor related to compliance with applicable laws; and (iii) additional questions, as required.

KEY PERFORMANCE INDICATORS

We are committed to upholding human rights globally and understanding, identifying, and addressing the risk of modern slavery in our operations and supply chains. We will regularly measure our progress against our commitments and continue to strengthen the efforts set forth above.

APPROVAL AND ATTESTATION

This statement was approved by the Board of Directors of StackAdapt UK Limited pursuant to the Modern Slavery Act 2015 (United Kingdom) on April 30, 2025.