ANTI‑SLAVERY STATEMENT OF floNET X

Last Updated: 23 April 2026

1. Our Commitment

floNET X ("we", "us", "our") is committed to conducting our business ethically and with integrity. We have a zero‑tolerance approach to modern slavery, forced labour, human trafficking, and all forms of exploitation. This statement is made pursuant to the Modern Slavery Act (UK) and similar transparency in supply chain legislation applicable in the Netherlands and the EU, reflecting our commitment to ensuring that neither our own operations nor our supply chains are involved in such practices.

2. Our Business and Supply Chains

floNET X designs, assembles, and sells floating fish cages with integrated solar roofs. Our products are engineered in the Netherlands and sourced from suppliers of:

• Steel and aluminium components (floating structures, solar panel frames)
• Solar photovoltaic panels and electrical components
• Synthetic nets, ropes, and mooring equipment
• Electronic controllers, inverters, and monitoring devices

We operate a lean supply chain with a limited number of trusted partners, primarily located in the Netherlands and other EU member states, as well as a small number of verified suppliers in Asia for specific components (e.g., solar panels, electronic parts). All suppliers are selected based on strict ethical criteria.

3. Policies and Due Diligence

We have implemented the following measures to prevent modern slavery in our operations and supply chains:

• Supplier Code of Conduct: All suppliers must agree to our Code of Conduct, which prohibits forced labour, child labour, human trafficking, and any form of involuntary servitude. Suppliers must comply with all applicable labour laws, including those relating to working hours, wages, health and safety, and freedom of association.
• Contractual Clauses: Our supply agreements include express clauses allowing us to terminate the contract immediately if a supplier is found to be using forced labour or human trafficking.
• Supplier Self‑Assessments: New and high‑risk suppliers complete a self‑assessment questionnaire covering labour practices, including recruitment, worker consent, wage payment, and document retention.
• Right to Audit: We reserve the right to conduct unannounced audits of our suppliers' facilities, including worker interviews and document reviews. Audits may be performed by our own staff or by independent third parties.
• Internal Training: Our procurement and management staff receive basic training on identifying indicators of modern slavery and reporting concerns.

4. Risk Assessment and Monitoring

We have assessed that the highest risk of modern slavery in our supply chain lies with component suppliers located outside the EU, particularly in jurisdictions where labour protections may be weaker. To mitigate this risk:

• We give preference to EU‑based suppliers where feasible.
• For non‑EU suppliers, we require third‑party certifications (e.g., SA8000, BSCI, or equivalent).
• We conduct annual reviews of all non‑EU suppliers, including a review of publicly available information and any allegations.

We consider the risk within our own operations (Netherlands) to be very low, as we comply with Dutch labour law and all employees are directly hired with full legal protections. However, we remain vigilant.

5. Reporting Concerns

We encourage all employees, contractors, suppliers, and other stakeholders to report any suspected instances of modern slavery or human trafficking without fear of retaliation. Reports may be made:

• Confidentially to: ethics@flonetx.com
• Anonymously via our whistleblower hotline (contact our office for details)

All reports will be investigated promptly and appropriate remedial action will be taken, up to and including termination of supplier relationships and referral to law enforcement authorities.

6. Effectiveness and Review

We continuously monitor the effectiveness of our anti‑slavery measures. This statement will be reviewed and updated annually, or more frequently if significant changes occur in our supply chain or operations.

7. Approval and Publication

This statement has been approved by the management of floNET X and is published on our website (flonetx.com) in accordance with legal requirements. It will be made available to any person or organisation upon request.

floNET X
The Netherlands
Email: ethics@flonetx.com (or info@flonetx.com)
Website: flonetx.com

Dutch Engineering. Since 2026. Zero tolerance for modern slavery.