Modern Slavery Statement

1. Director Statement

This Modern Slavery Statement is published by Skyrora Limited (the “Company”) pursuant to Section 54 of the Modern Slavery Act 2015 (“the Act”) and sets out the steps we have taken during the financial year ending 31 December 2025 to prevent modern slavery and human trafficking in our business operations and supply chains.

At Skyrora Limited, we are committed to conducting our business with integrity, transparency, and respect for human rights. We recognise that modern slavery, in all its forms (including forced labour, debt bondage, and human trafficking) represents one of the most egregious violations of human dignity. As a leading aerospace manufacturing business operating in Scotland and serving global markets, we understand our responsibility to ensure that our operations and supply chains are free from modern slavery and human trafficking.

The aerospace manufacturing sector is characterised by complex, multi-tiered global supply chains involving specialised materials, components, and sub-assemblies sourced from numerous jurisdictions. This complexity creates potential vulnerabilities that we take seriously. We are committed to continuous improvement in our due diligence processes, risk assessment methodologies, and supplier engagement strategies to identify, prevent, and mitigate modern slavery risks at every level of our supply chain.

This statement reflects our ongoing commitment to transparency and accountability. It outlines our organisational structure, the policies we have implemented, our due diligence processes, risk assessment and management approaches, key performance indicators, and training initiatives. We acknowledge that combating modern slavery requires sustained effort, collaboration with our suppliers and industry partners, and a willingness to evolve our practices in line with emerging best practices and regulatory expectations.

I am pleased to confirm that this statement has been approved by the Board of Directors of Skyrora Limited and reflects our collective commitment to ethical business practices and the protection of fundamental human rights.

Volodymyr Levykin

CEO

Skyrora Limited

2 February 2026

2. Our business and supply chains

2.1. Organisational Structure

Skyrora Limited is a private limited company incorporated in Scotland under company number SC569511. Our registered office is located at 7 Drum Mains Park, Cumbernauld, Glasgow G68 9LD, United Kingdom.

The Company operates as an aerospace design, manufacturing and assembly business. We operate facilities in Scotland, including our headquarters in Cumbernauld and our test site facilities in Midlothian.

Our organisational structure comprises the following key divisions:

  1. Manufacturing Operations
  2. Procurement and Supply Chain Management
  3. Quality Assurance and Compliance
  4. Human Resources
  5. Engineering and Design
  6. Finance and Administration
  7. Legal and Compliance.

The Company operates as part of the Skyrora Ventures group of companies.

2.2. Our supply chains

The aerospace manufacturing industry is characterised by extensive, complex, and multi-tiered supply chains. The Company’s supply chain encompasses the following key categories:

  1. Raw Materials and Metals
  2. Components and Sub-Assemblies
  3. Composite Materials
  4. Electronics and Avionics
  5. Machining and Surface Treatment Services
  6. Logistics and Freight
  7. Facilities Management and Support Services.

We work with a substantial number of direct suppliers across multiple countries. Our supply chain extends to multiple sub-tiers, with components and raw materials originating from diverse geographic regions, some of which are recognised as higher-risk for modern slavery and labour exploitation.

We acknowledge that the complexity and global nature of our supply chains create potential vulnerabilities to modern slavery risks, particularly in:

  1. Sub-tier suppliers where visibility and direct influence may be limited.
  2. Regions with weaker labour protections or known incidents of forced labour.
  3. Industries and sectors associated with vulnerable migrant worker populations.
  4. Subcontracted manufacturing or labour-intensive processes, such as surface treatment, assembly, and manual finishing.

3. Our policies on modern slavery and human trafficking

The Company has implemented a comprehensive framework of policies and procedures designed to prevent modern slavery and human trafficking in our operations and supply chains. These policies are reviewed annually and updated to reflect evolving best practices, regulatory requirements, and stakeholder expectations.

3.1. Modern slavery and human trafficking policy

Our standalone Modern Slavery and Human Trafficking Policy sets out our zero-tolerance approach to modern slavery in all its forms.

The Policy is available to all employees via our Handbook and training protocols and is communicated to suppliers as part of our onboarding and ongoing engagement processes.

3.2. Supplier Code of Conduct

Our Supplier Code of Conduct sets out the ethical, social, and environmental standards we expect from all suppliers. We reserve the right to audit suppliers’ compliance and to terminate relationships with suppliers who fail to meet our standards or refuse to implement corrective actions.

3.3. Recruitment and employment policies

Our internal recruitment and employment policies ensure that our own operations are free from modern slavery risks. Key provisions include:

  1. Fair Recruitment
  2. Right to Work Verification
  3. Employment Contracts
  4. Fair Remuneration
  5. Freedom of Movement
  6. Whistleblowing
3.4. Procurement and Contracting Policies

Our procurement policies integrate modern slavery considerations at every stage of the procurement lifecycle:

  1. Supplier Selection and Onboarding
  2. Contractual Provisions
  3. Ongoing Monitoring.
3.5. Grievance and Remediation Procedures

We have established procedures for receiving, investigating, and responding to reports of modern slavery. Our approach prioritises the safety and well-being of victims and includes provision for multiply reporting channels, prompt investigation, engagement with external experts, remediation actions and corrective actions with suppliers, or termination of the relationship in cases of severe or unresolved violations.

4. Due diligence processes

The Company has implemented a risk-based due diligence framework designed to identify, assess, prevent, and mitigate modern slavery risks across our operations and supply chains.

4.1. Supply chain mapping and transparency

We have undertaken a comprehensive mapping exercise to gain visibility into our supply chains, including direct supplier and sub-tier mapping, geographic risk profiling and sector/commodity risk profiling.

4.2. Supplier Risk Assessment

All existing and prospective suppliers undergo a modern slavery risk assessment. Our risk assessment process includes screening, risk categorisation, use of MSAT tools where appropriate and continuous monitoring.

4.3. Supplier Audits and Verification

Audits allow us to verify supplier compliance with our modern slavery requirements and may be desk-based, on-site, third-party conducted audits and unannounced audits as we deem appropriate.

4.4. Collaboration and Industry Engagement

We recognise that addressing modern slavery in complex aerospace supply chains requires collaboration. The Company may engage with industry and stakeholders including government and law enforcement.

4.5. Remediation and Responsible Disengagement

Where instances of modern slavery are identified or suspected, we take prompt action to respond immediately, investigate, create remediation plans and handle disengagement responsibly if required.

5. Risk assessment and management

5. Risk assessment and management

Within our own operations in Scotland, we have assessed modern slavery risks as low based on our current recruitment, employment, wages and benefits, employee reporting mechanisms.

However, we recognise residual risks may exist with contracted services or temporary labour, and we will conduct appropriate enhanced diligence in such cases.

5.2. Identified Risks in Our Supply Chains

Our supply chain risk assessment has identified higher-risk areas, particularly where sub-contracted services may involve increased risk (such as risk of use of migrant workers vulnerable to exploitation, i.e. within international logistics and freight sector). For each identified risk area, we implement targeted mitigation measures, including enhanced diligence and contractual requirements or alternative sourcing strategies where risks cannot be adequately mitigated.

6. Training and awareness

The Company is committed to ensuring that our employees, suppliers, and business partners have the knowledge and tools to identify, prevent, and respond to modern slavery risks.

6.1. Employee Training

All relevant employees receive modern slavery awareness training tailored to their roles and responsibilities, including general awareness training and role-specific training, annually and refreshed as required in response to emerging risks or changes in legislation.

6.2. Supplier Training and Capacity Building

We recognise that effective modern slavery prevention requires engagement and capacity building throughout our supply chain, and we offer support to suppliers to increase awareness.

7. Approval

This statement has been approved by the Board of Directors of Skyrora Limited on 2 February 2026 in accordance with Section 54(4) of the Modern Slavery Act 2015.

This statement is signed by a director of the Company as required by Section 54(6) of the Act.

 

Volodymyr Levykin

Director & Chief Executive Officer

Skyrora Limited

Date: 2 February 2026