Introduction f
Modern slavery and human trafficking are serious
violations of fundamental human rights. These
practices include slavery, servitude, forced or
compulsory labour, and human trafficking, all of
which involve the exploitation of individuals and the
deprivation of their freedom for personal or
commercial gain.
Cleohpatra is committed to conducting its business
in a lawful, ethical, and responsible manner. We have
zero tolerance for modern slavery and human
trafficking in any form and are committed to
implementing appropriate policies, controls, and
procedures to prevent such practices within our
operations and supply chains.
This statement sets out the steps Cleohpatra has
taken and continues to take to identify, mitigate, and
address risks related to modern slavery and human
trafficking within our business activities and supplier
relationships.

Our Organization
Cleohpatra GmbH and its affiliated entities
(“Cleohpatra”) are a technology and implementation
partner specializing in advanced data integration,
operational intelligence, and artificial intelligence
systems for complex organizations.
Founded in Germany in 2020, Cleohpatra works with
organizations across multiple industries to help them
integrate large-scale data environments, improve
operational decision-making, and deploy modern
enterprise technology platforms.
Our services include:
Data integration and analytics platforms
Artificial intelligence and advanced modelling
systems
Enterprise software implementation
Digital transformation initiatives
Technical consulting and engineering services
Cleohpatra operates internationally and collaborates
with clients and partners across Europe, the
Americas, and other regions.

Our Supply Chain
Cleohpatra’s supply chain primarily consists of
professional service providers, technology vendors,
and suppliers of office-related goods and services.
Examples of suppliers within our supply chain
include:
Professional services
Technology consultants
Legal advisors
Accounting and tax advisors
Marketing and communications firms
Technology and operational services
Cloud infrastructure providers
Software vendors and platform providers
IT services and managed service providers
Office services and goods
Logistics and delivery services
Office maintenance and facilities support
Computer hardware and related equipment
Office supplies and furniture
Due to the nature of our activities—primarily software
development, consulting, and technical
implementation—our direct exposure to sectors
traditionally associated with higher risks of forced
labour or human trafficking is limited.

Policies and Governance
Cleohpatra is committed to maintaining high
standards of corporate governance and ethical
conduct across all aspects of its operations.
We maintain internal policies and procedures
designed to ensure that our business activities are
conducted in accordance with applicable laws,
ethical standards, and internationally recognized
human rights principles.
These include:
Internal standards of professional conduct and
ethical business practices
Compliance with applicable labour and human rights
legislation
Supplier engagement practices designed to
encourage responsible business conduct
Cleohpatra expects employees, contractors, and
business partners to act with integrity and to comply
with all relevant laws and regulations relating to
labour rights and human dignity.

Risk Assessment and Due Diligence
Given the nature of Cleohpatra’s operations—
focused on highly skilled technical and consulting
services—we consider the direct risk of modern
slavery within our business operations to be low.
Nevertheless, we recognize that risks may arise
within broader supply chains, particularly where
goods or services may originate from jurisdictions or
industries with increased exposure to labour
exploitation.
To address these risks, Cleohpatra seeks to:
Engage reputable and established suppliers
Maintain transparency in procurement processes
Conduct appropriate due diligence when entering
into supplier relationships
We continue to review our procurement practices and
supplier relationships to identify opportunities to
further strengthen supply chain transparency.

Supplier Standards
Cleohpatra expects its suppliers and business
partners to share our commitment to ethical
business conduct and respect for human rights.
Where appropriate, Cleohpatra may incorporate
contractual provisions requiring suppliers to:
Comply with applicable labour and human rights laws
Avoid the use of forced, bonded, or involuntary labour
Maintain appropriate working conditions and labour
standards
We seek to build long-term relationships with
suppliers who demonstrate responsible business
practices and alignment with our values.
Reporting and Accountability
Cleohpatra encourages employees and external
stakeholders to raise concerns regarding unethical
conduct, including potential instances of modern
slavery or human trafficking.
Reports may be made through internal management
channels or through designated compliance
contacts.
Cleohpatra is committed to ensuring that individuals
who raise concerns in good faith are protected from
retaliation. All reported concerns are reviewed
appropriately and, where necessary, investigated in
accordance with applicable procedures.

Training and Awareness
As part of our ongoing governance and compliance
efforts, Cleohpatra aims to promote awareness of
ethical business practices and supply chain integrity
across the organization.
We intend to continue strengthening internal
awareness and training initiatives to help employees
understand the risks associated with modern slavery
and human trafficking and to ensure they are
equipped to identify and report potential concerns.

Continuous Improvement
Cleohpatra recognizes that addressing modern
slavery risks requires ongoing vigilance and
continuous improvement.
We remain committed to reviewing and strengthening
our policies, procedures, and governance frameworks
to ensure that our operations and supply chains are
conducted in a manner consistent with our ethical
standards and our respect for human rights.
At the date of this statement, Cleohpatra is not aware
of any instances of modern slavery or human
trafficking within its operations or supply chains.