UK Modern Slavery Act Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps SheerID has taken during the 2025-2026 financial year to help prevent modern slavery from taking place in our business and supply chains.

During the period covered by this statement, no modern slavery incidents were identified or reported to us.

Our business and operations

SheerID is a SaaS business and the leading global provider of permission-based verification of identity. Our award winning Audience Data Platform empowers marketers to create authentic connections by reaching and engaging valuable audience groups, including students, educators, healthcare workers and first responders.

SheerID operates as a remote-first company, with physical locations in Portland, Oregon and London, UK. SheerID conducts business in the UK and has a UK subsidiary, SheerID Ltd, and a UK office. SheerID Ltd has 12 employees who provide support in the UK and EMEA region across Sales, Customer Success and Verification Partnerships.

Our supply chains and third-party relationships

As a SaaS business, SheerID does not have a traditional supply chain. We do not use physical materials in the delivery of our software platform. Our supply chain primarily consists of technology, data and business services, including off-the-shelf and open source software, code developed by contractors, other SaaS services, data partners, subprocessors, marketing services, professional services and employee benefit providers.

Our commitment to preventing modern slavery

SheerID is committed to upholding the highest ethical and human rights standards. We strictly prohibit child labour, forced labour, slavery, servitude, debt bondage, human trafficking and other forms of forced or compulsory labour in our operations and supply chains.

We believe that all individuals should be treated with dignity and respect, and we do not tolerate any practices that violate fundamental human rights.

Policies supporting our approach

SheerID has in place policies which support its commitment to employment and labour rights. SheerID’s Child and Forced Labor Policy applies to all employees, directors, officers, contractors, suppliers, and any other individuals or entities working for or on behalf of SheerID globally. The policy sets expectations around legal compliance, prevention, due diligence, supplier responsibility, monitoring and reporting, remediation, and awareness and training.

SheerID’s wider ethics and compliance framework includes its Code of Conduct, respectful workplace policy, equal employment opportunities policy, anti-discrimination, anti-harassment and no retaliation policies, anti-corruption policy, reasonable accommodations policy and general complaint and investigation procedure policy.

Risk assessment

Given the nature of SheerID’s business as a SaaS provider, we assess the risk of modern slavery in our business and supply chains to be low.

However, we appreciate that risk can arise in any business relationship. Our relevant third-party risk areas include software and SaaS providers, code developed by contractors, data partners, subprocessors, marketing service providers, professional advisers and employee benefit providers.

Due diligence and controls

SheerID conducts due diligence to assess and address the risks of child labour and forced labour in its supply chains. Sheer ID requires suppliers to adhere to its Child and Forced Labor Policy and to implement their own policies and procedures to prevent child labour and forced labour.

SheerID has also established mechanisms for monitoring compliance and reporting concerns, and is committed to taking appropriate action to remediate any instances of child labour or forced labour that are identified.

SheerID maintains information security and privacy risk management processes designed to identify, assess, manage and monitor risks posed by third parties.

Training and awareness

SheerID requires employees to complete training during onboarding and annually thereafter, including security awareness, privacy awareness, security policies and harassment prevention training. Employees are also required to acknowledge receipt of the relevant employee handbook during onboarding.

Next steps

Over the next financial year, SheerID will continue to review its approach to modern slavery and human trafficking to maintain transparency and support continuous improvement. SheerID will also keep relevant UK legal developments under review, with support from UK counsel, and reflect any material updates in its next annual statement.

Approval and publication

This statement has been approved by the SheerID Board of Directors on June 24, 2026, and will be reviewed and updated annually.