Modern Slavery Statement

Last updated and reviewed on 12 December 2023

Introduction & Business Organization & Supply Chain

This Modern Slavery Statement (“Statement”) is made on behalf of Scaleflex SAS pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and Section 14 of the Australian Modern Slavery Act 2018. Scaleflex SAS is the parent company of 6 direct subsidiaries including Scaleflex Ltd and Scaleflex Inc. (hereinafter collectively referred as “Scaleflex”).

Scaleflex is a global SaaS provider of a Visual Experience platform that offers organizations a smart way to create, find and share creative files and branding materials. As a SaaS company Scaleflex key suppliers consist of (a) data centers that host its platform, (b) other SaaS providers; and (c) suppliers who enable Scaleflex to operate its facilities such as reception and security.

Policies & Training

It is essential for us to highlight the importance of compliance with human rights laws at the very start of the Scaleflex journey of our employees and suppliers. Therefore, as part of our onboarding package, every Scaleflex employee is required to complete a mandatory ethics training highlighting the importance of compliance with human rights laws. Similarly, we expect our key suppliers (i) to have sufficient anti-slavery and human trafficking policies and procedures in place; and (ii) commit to the core values of United Nations Global Compact.

In our employee handbooks and supplier policies, we communicate our values to our employees and suppliers and emphasize that we do not tolerate violations of human rights laws. On a regular basis we review our policies to ensure that they stay up-to-date and compliant with the current legislation and practices.

Due Diligence and Risk Assessment

Staying vigilant against any possible violations of human rights within our organization and supply chain is essential for us. Therefore, every person within our organization has the responsibility to prevent, detect and report suspected violations of this Statement, human rights principles or other laws and regulations taking place in any part of our organization or supply chain. Any suspected violation can be reported to Scaleflex Legal Team directly at

Next Steps

We are committed to respecting human rights as set out in the UN Guiding Principles on Business and Human Rights, UN Universal Declaration of Human Rights, Core Conventions of the ILO and ILO Declaration on Fundamental Principles and Rights at Work.

Therefore, in addition to the current mechanisms we have, we are in the process of developing a specific anti-slavery and human trafficking module to take place in our ethics/onboarding training. This new module is expected to be published during 2024 and will be mandatory for all employees. Upon incorporation of this module, this Statement shall be updated accordingly.

This Statement shall be reviewed before the end of each financial year and amended as required by any significant changes in the legislation.

Emil Novakov

Chief Executive Officer

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