Modern Slavery Statement

Financial Year Ending: 2025

Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes our Modern Slavery Statement for the financial year ending 2025. This statement sets out the steps taken by Mimoto, Inc. (“the Company,” “we,” “us,” or “our”) to prevent modern slavery and human trafficking in our business operations and supply chains.

Our Organization

Mimoto, Inc. is an AI-powered cybersecurity company headquartered in San Francisco, CA, USA. We operate in one country and employ approximately eight (8) people worldwide. 

Our Business Structure

  • Legal Structure: a Delaware C-corporation
  • Primary Activities: Mimoto delivers continuous CAPTCHA and continual validation of who or what is interacting with systems and applications based on a specific person, not a credential, for real-time response to ransomware, insider threats, and agentic attacks, before damage is done.
  • Geographic Presence: primarily in the United States of America
  • Key Sectors: Cybersecurity and AI

Our Supply Chains

We recognize that modern slavery risks can exist at any tier of our supply chain. Our supply chains include:

  • Direct Suppliers: Three (4) suppliers providing engineering services, creative services, UI/UX services, and web-development services
  • Geographic Distribution: Suppliers located across the United States, European Union, LATAM.
  • High-Risk Categories: We have identified the following as potentially higher-risk categories:
    • Temporary staffing agencies

Supply Chain Due Diligence

We conduct due diligence on our suppliers through:

  • Pre-qualification assessments
  • Supplier self-assessment questionnaires
  • Suppliers’ audits and site visits of their suppliers
  • Certification requirements (as applicable)

Policies and Governance

Our Commitment

We are committed to:

  • Conducting business ethically and with integrity
  • Respecting human rights throughout our operations
  • Ensuring compliance with applicable laws and regulations
  • Working with suppliers who share our values

Key Policies

  • Code of Conduct: Establishes our ethical standards and expectations
  • Supplier Code of Conduct: Requires suppliers to meet minimum labor standards
  • Whistleblowing Policy: Provides safe channels for reporting concerns
  • Procurement Policy: Integrates modern slavery considerations into purchasing decisions

Governance Structure

  • Board Oversight: The Board of Directors has ultimate responsibility for this statement
  • Executive Responsibility: R&D executives are responsible for implementation
  • Working Group: Cross-functional team monitors compliance and improvement initiatives

Risk Assessment and Management

Risk Identification

We have identified potential modern slavery risks in:

  • Business Model Risks: Use of temporary or contract labor
  • Sub-supplier Risks: Suppliers chosen by our suppliers

Risk Mitigation Measures

  • Enhanced due diligence for high-risk suppliers
  • Regular supplier audits and assessments
  • Contractual provisions requiring compliance with labor standards
  • Training programs for procurement and operational staff
  • Grievance mechanisms for workers and suppliers

Training and Awareness

We provide training on modern slavery awareness to:

  • Procurement Teams: Specialized training on supply chain risks
  • Management: Leadership training on modern slavery risks and responsibilities
  • All Employees: General awareness training through our learning management system
  • Suppliers utilize: Resources and guidance on identifying and preventing modern slavery

Training covers:

  • Recognition of modern slavery indicators
  • Reporting procedures and escalation paths
  • Legal requirements and company policies
  • Best practices for supplier management

Monitoring and Effectiveness

Key Performance Indicators

We measure our effectiveness through:

  • Training completion rates across the organization
  • Number of concerns raised through grievance mechanisms

In addition, we also measure our effectiveness through the use of third-parties to assess:

  • Suppliers for modern slavery risks
  • High-risk suppliers through annual audits
  • Supplier compliance scores

Third-parties Conducted Monitoring Activities

  • Annual supplier assessments: Supplier assessments
  • On-site audits: Audits conducted in the reporting period
  • Worker interviews: Direct engagement with workers during site visits

Areas for Improvement

We recognize areas where we can strengthen our approach:

  • Enhanced our supplier assessment questionnaire to include specific modern slavery questions
  • Expanding audit coverage to include our suppliers’ suppliers
  • Enhancing data collection on supply chain transparency
  • Developing more sophisticated risk assessment tools

Looking Forward

Priorities for Next Reporting Period

  • Provided modern slavery training to all employees
  • Updated our Supplier Code of Conduct to strengthen labor standards requirements
  • Implemented new supplier onboarding procedures including enhanced due diligence
  • Enhance collaboration with industry peers and NGOs
  • Develop key performance indicators to better measure progress
  • Strengthen grievance mechanisms and remediation procedures

Continuous Improvement

We are committed to:

  • Regular review and updating of our policies and procedures
  • Ongoing engagement with stakeholders including suppliers, customers, and civil society
  • Investment in technology and systems to improve supply chain transparency
  • Collaboration with industry initiatives and multi-stakeholder programs

Approval

This statement has been approved by the Board of Directors of Mimoto, Inc.

This statement will be reviewed annually and updated as necessary to reflect our ongoing commitment to preventing modern slavery in our business and supply chains.

Date Sided: August 3, 2025

A signed copy of this statement is available for download to pertinent organizations and individuals.