Modern Slavery Statement

Geopera Pty Ltd (ACN registered in Australia) ("Geopera", "we", "us" or "our") is committed to operating ethically, lawfully and with integrity in every part of our business. We condemn modern slavery in all its forms and do not tolerate any conduct in our operations or supply chains that constitutes, contributes to, is linked with, or causes Modern Slavery as defined in the Modern Slavery Laws of Australia.

This statement sets out the steps Geopera has taken, and continues to take, to assess and address modern slavery risks in our operations and supply chains. We publish this statement voluntarily. Although Geopera does not currently meet the mandatory reporting threshold under the Modern Slavery Act 2018 (Cth) of AUD $100 million in consolidated revenue, we recognise that the satellite imagery and geospatial technology industry has supply chain touchpoints (manufacturing, data acquisition, cloud infrastructure, contracted services) that warrant proactive due diligence. We have therefore chosen to align our practices with the expectations set out in the Modern Slavery Act 2018 (Cth), the Modern Slavery Act 2018 (NSW), and the guidance issued by the NSW Anti-slavery Commissioner.

Geopera will not knowingly engage with any supplier, partner, contractor or customer that engages in Modern Slavery, and we expect those we work with to hold themselves to the same standard.

This statement applies to Geopera Pty Ltd and any entities it owns or controls. It covers all directors, officers, employees, contractors, secondees, agents, consultants and interns working for or on behalf of Geopera, and applies to all of Geopera's operations and supply chains wherever located.

This statement is intended to be read together with our Commercial Terms of Service, Privacy Policy and Usage Policy. Where any term in this statement conflicts with a more specific contractual obligation, the contractual obligation prevails.

This statement is reviewed at least annually and updated as our operations, supply chains, risk landscape or applicable laws change.

In this statement, the following definitions apply. They have been adopted from the Modern Slavery Laws and are intended to align with the contractual definitions used by Australian government and enterprise procurement entities.

We have assessed the inherent modern slavery risks across our operations and supply chains taking into account sector, geography, product/service category and entity-level factors. Our assessment draws on the Global Slavery Index, the Walk Free Foundation data, the US Department of Labor's List of Goods Produced by Child Labor or Forced Labor, guidance from the Australian Border Force and the NSW Anti-slavery Commissioner.

We apply a risk-based, proportionate due diligence approach that is escalated for higher-risk supplier categories and geographies. Our approach is informed by the United Nations Guiding Principles on Business and Human Rights and the OECD Due Diligence Guidance for Responsible Business Conduct.

Where Geopera is a party to a contract that requires it to take Reasonable Steps in accordance with the NSW Anti-slavery Commissioner's Guidance on Reasonable Steps, Geopera will:

• adopt and maintain governance arrangements appropriate to the size of our business to oversee modern slavery risk;
• identify and assess modern slavery risks in our operations and supply chains relevant to the contract, using a risk-based methodology that considers sector, geographic, product/service and entity-level factors;
• take action to prevent, mitigate and, where appropriate, remediate Modern Slavery that Geopera causes, contributes to or is directly linked to, proportionate to the severity and likelihood of the risk and Geopera's leverage;
• embed expectations into supplier and subcontractor arrangements through contract terms, codes of conduct and on-boarding processes;
• provide accessible grievance mechanisms and protect those who raise concerns from retaliation;
• measure the effectiveness of these actions and continuously improve them; and
• co-operate transparently with the principal under the contract, including by providing information reasonably required to demonstrate that Reasonable Steps have been taken.

Geopera will keep its approach to Reasonable Steps current as the NSW Anti-slavery Commissioner's guidance is updated from time to time.

Suppliers, contractors and partners engaged by Geopera are expected to:

• not engage in, cause or contribute to Modern Slavery in connection with the goods or services they supply to Geopera, our affiliates or our customers;
• comply with all applicable Modern Slavery Laws and with internationally recognised labour standards, including the ILO Declaration on Fundamental Principles and Rights at Work;
• pay workers at least the legally applicable minimum wage and ensure all overtime is lawful, voluntary and properly compensated;
• not charge workers recruitment fees, retain identity or travel documents, or restrict freedom of movement, association or grievance;
• maintain effective grievance mechanisms accessible to their workers and supply chain;
• promptly notify Geopera of any actual, suspected or alleged Modern Slavery related to goods or services provided to us, and of any material non-compliance with Modern Slavery Laws; and
• co-operate with reasonable Geopera and customer requests for information, audits and remediation, including where required to enable Geopera to comply with modern slavery contract clauses with its own customers.

Geopera reserves the right to require corrective action, withhold payment pending investigation, or terminate any supplier arrangement where there is credible evidence of Modern Slavery that the supplier is unable or unwilling to address.

We brief relevant personnel — particularly those involved in procurement, vendor management, partnerships, sales and people operations — on the requirements of this statement and how to identify potential modern slavery indicators. Briefings cover:

• what Modern Slavery is, including the specific offences captured by the Modern Slavery Laws;
• how to assess supplier and partner risk, with emphasis on geographies and categories of elevated concern;
• red flags that may indicate Modern Slavery in operations or supply chains; and
• how to escalate concerns internally and to external authorities where appropriate.

Modern slavery awareness is integrated into on-boarding for new employees and reinforced through ongoing supplier and contract reviews.

Where Geopera identifies that it has caused or contributed to Modern Slavery, we will:

• take prompt action to stop the conduct and prevent recurrence;
• provide, or co-operate in providing, effective remedy to affected persons, having regard to their stated needs and to applicable laws;
• report the conduct to relevant law-enforcement or regulatory authorities where required or appropriate;
• work with the supplier or business partner to address the root cause, including corrective-action plans, capacity-building and time-bound improvements;
• review and update our controls so that the conduct is less likely to occur again; and
• treat termination of a relationship as a last resort, recognising that withdrawal can deepen harm to affected workers; where Geopera does exit a relationship, we will seek to do so responsibly.

Where Geopera is directly linked to Modern Slavery through a business relationship (rather than causing or contributing to it), Geopera will use its available leverage to seek to influence the relevant party to prevent or mitigate the harm.

Anyone — employees, contractors, suppliers, supplier workers, customers, community members — who has information about actual or suspected Modern Slavery connected to Geopera's operations or supply chains is encouraged to report it. Reports may be made confidentially to:

Reports may be made anonymously. Geopera prohibits any form of retaliation against anyone who in good faith raises a concern or co-operates with an investigation.

Serious matters may also be reported externally to:

• the Australian Federal Police on 131 AFP (131 237) in non-urgent matters, or 000 in an emergency;
• the NSW Anti-slavery Commissioner via the published reporting channels on the NSW Government website; and
• the Fair Work Ombudsman for workplace exploitation matters arising in Australia.

Where Geopera submits a response to a request for proposal, tender, quotation or other procurement process and is subsequently awarded a contract, Geopera acknowledges and agrees that the pricing or compensation submitted in its response has been determined such that performance of the resulting contract can be carried out without causing or contributing to Modern Slavery.

Geopera further acknowledges and agrees that, if awarded such a contract, it may be required to comply with modern slavery contract clauses incorporated into that contract, and Geopera will provide, or enable the provision of, an effective remedy to any Modern Slavery that it does cause or to which it does contribute.

Geopera factors the cost of responsible sourcing, fair compensation and supplier oversight into its pricing models and does not knowingly compete on the basis of cost structures that would only be achievable through exploitative practices.

We measure the effectiveness of our modern slavery program through a combination of qualitative and quantitative indicators, including:

• the proportion of higher-risk suppliers assessed and on-boarded with appropriate due diligence;
• the proportion of higher-risk supplier contracts that include modern slavery clauses;
• the number of modern slavery concerns reported, investigated, substantiated and remediated;
• the timeliness and adequacy of remediation provided;
• the completion of relevant briefings and training by relevant personnel;
• findings from internal reviews and any external audits or assessments; and
• feedback from customers, suppliers and workers on our grievance and remediation processes.

Findings from these measures inform updates to our policies, controls and training.

Overall accountability for this statement and for Geopera's modern slavery program rests with the Board of Geopera Pty Ltd. Day-to-day responsibility for implementation is delegated to Geopera's executive team, with operational ownership across legal, procurement, people operations and the relevant business owners of supplier relationships.

This statement has been prepared in consultation with the entities and functions whose activities it covers, and is approved by the Board of Geopera Pty Ltd.

This statement is reviewed at least annually and may be updated more frequently to reflect changes in our operations, supply chains, risk landscape, the Modern Slavery Laws or guidance from the NSW Anti-slavery Commissioner. The current version is always available at geopera.com/legal/modern-slavery.

Questions about this statement, or requests to discuss Geopera's modern slavery program, can be directed to: