Modern Slavery Statement

This statement is made pursuant to the Modern Slavery Act 2018 (Cth) and sets out the steps Admiral Operations Pty Ltd (ACN 693 495 304) of Level 11, 49-51 York Street, Sydney, NSW, 2000, Australia, and its related entities, have taken during the reporting period to assess and address the risks of modern slavery in our operations and supply chain.

About Admiral

Admiral is a software platform company headquartered in Sydney, Australia. We provide an operating system and control plane for operators of Linux edge device fleets. We do not manufacture physical goods; our operations are primarily digital.

Our commitment

Admiral is committed to operating ethically and with integrity. We have a zero-tolerance approach to modern slavery, including forced labour, servitude, human trafficking, debt bondage, forced marriage, and the worst forms of child labour.

We expect the same ethical standards from every organisation we engage with, including customers, suppliers, contractors, and partners.

Our operations

Our team is primarily engaged in software engineering, sales, and customer success. Staff are employed directly under Australian employment law and international equivalents. We do not use labour-hire agencies for core operations.

Our supply chain

Our supply chain is comparatively low-risk. The goods and services we procure are primarily:

• Cloud infrastructure and SaaS services from major providers
• Professional services (legal, accounting, marketing)
• Office supplies, furniture, and IT hardware
• Occasional hardware samples for testing and reference purposes

We acknowledge that hardware procurement, particularly electronic devices, carries elevated modern slavery risk globally. We address this through supplier due diligence as described below.

Risk assessment

We assess modern slavery risk across our supply chain using the following criteria:

• Sector and industry risk
• Geographic risk, particularly for suppliers operating in higher-risk jurisdictions
• Workforce risk, including use of migrant or base-skill labour
• Product and services risk

Our actions

During this reporting period we have taken the following steps:

• Established this Modern Slavery Statement and supporting policies
• Included modern slavery obligations in our standard supplier and customer agreements
• Conducted due diligence on material new suppliers, with a focus on hardware and manufacturing partners
• Provided training to our team on identifying and reporting modern slavery concerns
• Established an internal grievance and reporting mechanism

Reporting concerns

Any person, including staff, contractors, suppliers, customers, and members of the public, who has concerns about modern slavery practices in our operations or supply chain may raise them in confidence by emailing ethics@admrl.co.

We take every report seriously and investigate promptly. We do not tolerate retaliation against anyone who raises a concern in good faith.

Assessing effectiveness

We review the effectiveness of our modern slavery programme annually. We assess the adequacy of our policies, the coverage of our due diligence, the responsiveness of our grievance channels, and the outcomes of any investigations undertaken.

Consultation

This statement was prepared in consultation with our leadership team and approved by the board of Admiral Operations Pty Ltd.

Contact

For questions about this statement or our modern slavery programme, contact us at ethics@admrl.co or by post to: Admiral Operations Pty Ltd, Level 11, 49-51 York Street, Sydney, NSW, 2000, Australia.