Modern Slavery Act Statement

This statement is made on behalf of Frontal Labs, Inc. ("Frontal," "we," "us," or "our") pursuant to Section 54(1) of the UK Modern Slavery Act 2015, the California Transparency in Supply Chains Act of 2010 (SB 657), the Australian Modern Slavery Act 2018 (Cth), and Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (S.C. 2023, c. 9). This statement sets forth the steps Frontal has taken during the financial year ending December 31, 2025, to identify, assess, and mitigate the risk of modern slavery, forced labor, child labor, and human trafficking in our operations and supply chains.

1. OUR BUSINESS AND ORGANIZATIONAL STRUCTURE

Frontal Labs, Inc. is a Delaware corporation with its registered address in Newark, Delaware, United States of America. Frontal is a fully remote company with team members located primarily in Portugal and across Europe. Frontal provides enterprise software, artificial intelligence infrastructure, cloud services, APIs, databases, storage, and developer tools to organizations worldwide. Frontal publishes this statement voluntarily as part of its commitment to transparency and ethical business practices. Where applicable statutory revenue thresholds are met, this statement is made pursuant to the legislation identified above. Frontal is not a retail seller or manufacturer as defined under the California Transparency in Supply Chains Act and publishes the relevant disclosures voluntarily.

2. OUR SUPPLY CHAIN

Frontal's supply chain consists primarily of:

Cloud infrastructure and hosting services (including Amazon Web Services, Google Cloud Platform, and Microsoft Azure).
Enterprise software and SaaS subscriptions for internal business operations.
Professional services, including legal, accounting, consulting, and marketing services.
Office equipment, supplies, and facilities services.
Third-party AI model providers and technology partners.

As a provider of software and cloud-based services, our operations and supply chain are not in sectors traditionally associated with a high risk of modern slavery, forced labor, or human trafficking. Our direct suppliers are primarily large, established technology and professional services companies headquartered in jurisdictions with robust legal frameworks addressing labor rights.

3. OUR POLICIES AND COMMITMENTS

Frontal maintains the following policies and commitments relevant to the prevention of modern slavery and human trafficking:

Code of Conduct. All Frontal personnel, including employees, contractors, and officers, must adhere to our Code of Conduct, which prohibits practices that violate human rights, labor laws, or the dignity of any person. The Code of Conduct is provided to all personnel at onboarding and compliance is reinforced through annual training.
Supplier Code of Conduct. Frontal expects its suppliers and business partners to adhere to ethical labor practices, comply with all applicable wage and hour laws, prohibit forced labor and child labor, and maintain safe working conditions. The Supplier Code of Conduct is incorporated into our supplier agreements.
Whistleblower Policy. Frontal maintains a confidential reporting mechanism for personnel to report concerns about unethical conduct, including concerns related to modern slavery, human trafficking, or labor violations, without fear of retaliation. Reports may be made to compliance@frontal.dev.
Human Rights Policy. Frontal is committed to respecting human rights in accordance with the UN Guiding Principles on Business and Human Rights. Frontal does not tolerate any form of forced labor, bonded labor, involuntary prison labor, child labor, or human trafficking in any part of its business or supply chain.
Employment Practices. Frontal verifies the right to work of all employees, pays at or above applicable minimum wage, provides legally mandated benefits, prohibits withholding of identity documents, and ensures employment is freely chosen. All Frontal personnel work under written agreements that clearly state the terms and conditions of their engagement.

4. RISK ASSESSMENT AND DUE DILIGENCE

Frontal has conducted a risk assessment of its operations and supply chain to identify potential risks of modern slavery and human trafficking. Our assessment considered geographic risk factors, industry risk factors, and the nature of services provided.

Based on this assessment, Frontal considers its overall risk exposure to modern slavery and human trafficking to be low due to:

The nature of our business as a software and cloud services company.
Our limited reliance on physical supply chains and manufacturing.
Our concentration of suppliers in low-risk jurisdictions and sectors.
Our limited use of temporary or contingent labor.

We recognize that risks may be higher in connection with hardware manufacturing (for office equipment), janitorial and facilities services, and certain professional services. We continue to monitor these areas.

5. SUPPLIER DUE DILIGENCE

Frontal's supplier onboarding process includes:

Review of supplier's business practices, reputation, and public disclosures regarding labor practices.
Inclusion of compliance with modern slavery and human trafficking laws in supplier contracts.
Requirement that suppliers represent their compliance with applicable labor and human rights laws.
Ongoing monitoring of supplier relationships for risk indicators.

For suppliers in higher-risk categories or jurisdictions, we may require additional due diligence, including supplier questionnaires, certifications, or independent audit reports.

6. TRAINING

Frontal provides training on modern slavery and human trafficking awareness to personnel in relevant roles, including:

Human resources and people operations.
Procurement and supply chain management.
Legal and compliance.
Executive leadership.

Training covers the identification of modern slavery risk indicators, reporting obligations, and Frontal's policies and commitments.

7. EFFECTIVENESS AND KEY PERFORMANCE INDICATORS

Frontal monitors the effectiveness of its modern slavery prevention measures through:

Number of modern slavery-related reports received and investigated (financial year 2025: zero reports).
Number of suppliers assessed for modern slavery risk.
Percentage of relevant personnel completing modern slavery awareness training.
Number of supplier contracts incorporating modern slavery compliance provisions.

We will continue to refine our metrics and monitoring processes.

8. CONSULTATION AND APPROVAL

This statement has been reviewed and approved by the Board of Directors of Frontal Labs, Inc.

Signed: Gabriel Fonseca Chief Executive Officer Frontal Labs, Inc. Date: June 11, 2026

9. FUTURE STEPS

In the coming financial year, Frontal commits to:

Expanding modern slavery due diligence coverage for our supply chain.
Enhancing supplier monitoring processes.
Reviewing and updating our Supplier Code of Conduct.
Continuing training and awareness programs.

10. CONTACT

Questions regarding this statement or Frontal's modern slavery compliance program may be directed to:

Frontal Labs, Inc. Attn: Legal and Compliance 131 Continental Drive, STE 305 Newark, DE 19713 United States of America Email: compliance@frontal.dev