Modern Slavery and Human Trafficking Statement

1. About this statement

This is the statement of AVONAO, INC. ("we", "us"), the company that provides Avonao ID, on the risks of modern slavery and human trafficking in our business and our supply chains and what we do about them. "Modern slavery" here means slavery, servitude, forced or compulsory labour, debt bondage, deceptive recruitment for labour, the worst forms of child labour and human trafficking.

It is voluntary. None of the three laws it follows requires a statement from us:

We publish it because customers ask about modern slavery when they review us as a supplier, and one public answer is better than many private ones. It follows each law's criteria so that it can be read beside a statutory statement: sections 2 to 7 cover the topics of section 54(5) of the UK Act and the mandatory criteria of section 16 of the Australian Act, and section 8 gives the five disclosures the California Act asks for.

Voluntary reporting under the Australian Act begins with a notice to the Australian Minister. We have not given one, so this statement is not on the Australian Modern Slavery Statements Register.

2. Our structure, operations and supply chains

Structure. AVONAO, INC. is a corporation formed in the State of Delaware, USA, with its address at 254 Chapman Rd, Ste 208 #21918, Newark, Delaware 19702, USA (legal address). Our mailing address, for general correspondence only, is AVONAO, INC., 2261 Market Street PMB 10671, San Francisco, CA 94114, United States. It is not our legal address: all legal correspondence must be sent to the legal address in Delaware stated above (see the Imprint). This statement covers AVONAO, INC.

Operations. We build and run Avonao ID, an online account and sign-in service, and the Avonao platforms (Agined, Intramedial, Trustvice and GoPlainly), with Avonao Billing as the central billing entity for them. We sell online to people and businesses around the world. We do not make, import or resell physical goods. Our work is software development, operations, customer support and administration.

Supply chains. What we buy falls into three groups:

1. Cloud and software services. Hosting, databases and networking (Cloudflare), payments (Stripe), company mailboxes (Microsoft 365), sign-in at your own choice (Google, Microsoft and GitHub) and the other providers on our Sub-processors page, together with the software tools our team works with.
2. Computer equipment that our team uses, such as laptops.
3. Professional services, such as legal, accounting and tax advice.

3. Where the risks are

The work in our own operations is skilled software and office work, which carries a low risk of modern slavery. The risks sit further along our supply chains, with our suppliers and their suppliers:

• Electronics. The servers, network equipment and devices that our cloud providers run, and our own computers, depend on electronics manufacturing and on minerals such as cobalt, tin, tantalum, tungsten and gold. Forced labour and child labour have been documented in the mining, refining and assembly behind them.
• Data centre services. Construction, cleaning and security at data centres are often subcontracted, a pattern that has been linked to labour exploitation.

We do not cause these risks, but we could be linked to them through what we buy.

4. What we do

• We buy mainly from large providers that report on these risks themselves. Most of our main suppliers, among them Cloudflare, Google, Microsoft and Stripe, publish their own modern slavery statements.
• We take reports seriously. Anyone, inside or outside the company, can tell us about a concern at support@avonao.com. We will look into every report, and we will not penalise anyone for making one in good faith.

This statement is our policy on modern slavery. We do not yet have a separate written policy, supplier audits or specific training; section 8 says so in the terms of the California Act.

5. Next steps

1. Add a clause on forced labour and human trafficking to a short code that our suppliers accept.
2. When we choose or renew a main supplier, check whether it publishes a modern slavery statement, and keep a record of what we found.
3. Review this statement every year.

6. How we will measure progress

We will judge our progress by whether the steps in section 5 are done, by the share of our main suppliers that publish a modern slavery statement, and by the number of reports we receive and how each was resolved. The next version of this statement will report on all three.

7. Training and consultation

We do not yet give specific training on modern slavery and human trafficking. AVONAO, INC. prepared this statement itself.

8. California Transparency in Supply Chains Act disclosures

The California Act asks a company to disclose to what extent, if any, it does five things. Our answers:

1. Verification. We do not engage third parties to verify our supply chains for risks of human trafficking and slavery. We rely on our suppliers' own published statements.
2. Audits. We do not audit our suppliers for compliance with our standards on human trafficking and slavery.
3. Certification. We do not require our direct suppliers to certify that the materials in their products comply with the laws on slavery and human trafficking of the countries where they do business.
4. Internal accountability. We do not yet have written internal standards and procedures for employees or contractors who fail to meet company standards on slavery and trafficking. This statement and the supplier code in section 5 will be the basis for them.
5. Training. We do not yet train employees and managers with direct responsibility for supply chain management on human trafficking and slavery.

9. Approval

The Chief Executive Officer of AVONAO, INC. approved this statement.

Signed for and on behalf of AVONAO, INC. by its Chief Executive Officer.

10. Contact

Questions about this statement: support@avonao.com.