Modern Slavery and Human Trafficking Statement

NewRocket, LLC and NewRocket (UK) Ltd — Financial Year Ended 31 December 2025

Introduction

This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 by NewRocket, LLC ("NewRocket" or the "Company") on its own behalf and on behalf of its wholly owned subsidiary NewRocket (UK) Ltd. It is a group statement covering both entities and sets out the steps taken during the financial year ended 31 December 2025 to identify and address the risk of modern slavery and human trafficking in the group's operations and supply chain.

NewRocket's total turnover for the financial year ended 31 December 2025, calculated as the turnover of the Company together with its subsidiary undertakings, exceeds the £36 million threshold prescribed under section 54. The group carries on business in the United Kingdom and supplies services, and accordingly falls within the reporting requirement. This is the group's first published statement of this kind.

Organization Structure and Business

NewRocket, LLC is a company incorporated in the United States and is the ultimate parent of the group. NewRocket (UK) Ltd is a wholly owned subsidiary of NewRocket, LLC and is the entity through which the group carries on business in the United Kingdom. Both entities are covered by this statement, and both operate under the same group policies, governance structure, and delivery model described below.

NewRocket is a remote-first professional services group that provides ServiceNow consulting, implementation, and managed services to enterprise clients. The group operates in the United States, Canada, the United Kingdom, the Netherlands, and India, and delivers its services through a professional, salaried and contracted workforce.

NewRocket does not manufacture physical products and does not operate supply chains involving raw materials, agricultural goods, or physical manufacturing. Client work is performed within the client's own ServiceNow environment. The group's procurement is concentrated in a small number of enterprise software and cloud service providers, together with professional subcontractors and staffing suppliers engaged to support delivery.

Policies

The group maintains a Modern Slavery and Human Trafficking Policy that applies to all employees, independent contractors, consultants, and business partners across both NewRocket, LLC and NewRocket (UK) Ltd, regardless of geographic location. The policy sets out the group's opposition to slavery, servitude, forced or compulsory labor, debt bondage, child labor, and human trafficking in all forms, and assigns accountability for compliance across Executive Leadership, Human Resources, Vendor Management, and Legal.

The policy is supported by the group's Environmental, Social and Governance Policy, Supplier Diversity Policy, and standard confidentiality and acceptable use agreements entered into by all personnel at onboarding. Policies are reviewed at least annually by the Legal team and promptly following any material legislative change or change in the group's business model or geographic footprint.

Risk Assessment

NewRocket assesses the group's inherent exposure to modern slavery as low. The group employs a skilled professional workforce, engages no manual or seasonal labor, operates no manufacturing or logistics facilities, and does not source physical goods at scale. Compensation is professional-grade and paid at or above applicable statutory minimums in every jurisdiction of operation, including the United Kingdom.

The group recognizes that a low inherent risk is not the same as no risk. The areas identified as carrying the greatest residual exposure are the engagement of subcontractors and staffing intermediaries, particularly where delivery resources are sourced through third parties, and the extended technology supply chain beyond the group's direct suppliers, where visibility is necessarily limited.

Due Diligence and Steps Taken

During the financial year ended 31 December 2025, NewRocket took the following steps across both entities to address modern slavery risk in the group's operations and supply chain:

  • Reviewed, updated, and formally approved the Modern Slavery and Human Trafficking Policy, aligning it to the UK Modern Slavery Act 2015, the California Transparency in Supply Chains Act, the Netherlands Child Labor Due Diligence Act, ILO core labor standards, and the UN Global Compact.
  • Verified the identity and right to work of all employees and contractors in accordance with applicable local legislation as part of the onboarding process.
  • Maintained a no-fee recruitment position, under which no recruitment fee is charged to any worker, and required recruitment agencies and labor providers engaged by the group to operate on the same basis.
  • Incorporated anti-slavery and human trafficking compliance requirements into vendor onboarding, and assessed new vendors and contractors for risk prior to engagement, applying more detailed due diligence to higher-risk relationships.
  • Included in supplier and contractor agreements the right to audit for compliance and the right to terminate the relationship in the event of a material breach.
  • Maintained reporting channels through which employees and contractors can raise concerns in good faith, with protection from retaliation for those who do so.

Effectiveness

NewRocket received no reports, allegations, or substantiated findings of modern slavery or human trafficking within the group's operations or supply chain during the financial year ended 31 December 2025. No supplier relationship was terminated on modern slavery grounds, and no remediation action was required.

The group acknowledges that the absence of reports is not by itself evidence of effectiveness. Accordingly, the priorities set out below are directed at strengthening the group's ability to detect and evidence compliance rather than solely to assert it.

Priorities for the Coming Year

NewRocket has identified the following areas for development across the group in the coming financial year:

  • Introduce modern slavery awareness content into the group's annual compliance training, enabling personnel to recognize warning signs and understand how to escalate a concern. No dedicated modern slavery training was delivered during the year under review.
  • Formalize the schedule and documentation of periodic modern slavery risk assessments, so that assessment activity is recorded and auditable.
  • Extend due diligence coverage across the existing supplier base, rather than at onboarding alone, with a defined reassessment cadence for higher-risk relationships.
  • Establish measurable indicators, such as supplier assessment coverage and training completion rates, against which the effectiveness of these steps can be reported in future statements.

Approval

This statement was approved by the Board of Directors of NewRocket, LLC, on its own behalf and on behalf of NewRocket (UK) Ltd, on 08/01/2026. It is signed on behalf of the Board by Harsha Kumar, Chief Executive Officer.

Signed:

Name: Harsha Kumar
Title: Chief Executive Officer
Date: 08/01/2026

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