Vantrue
Modern Slavery Act 2015
Transparency Statement

Reporting period: January 2025 – Dec 2025

Publication date: 12^th June 2026

1. Statement of Commitment

Vantrue is committed to conducting business with high standards of ethics, integrity and social responsibility. We maintain a zero-tolerance approach to modern slavery, forced labour, human trafficking, child labour and debt servitude in our business operations and supply chains. We expect the same standards from our employees, suppliers, contractors, manufacturing partners and logistics providers.

This statement describes the steps Vantrue has taken during the reporting period to identify, prevent, mitigate and respond to modern slavery risks in its business and supply chains. It is intended to support transparency under section 54 of the Modern Slavery Act 2015 where the Act applies to the relevant Vantrue organisation(s).

2. Organisation, Business and Supply Chain

Vantrue designs, manufactures and distributes smart Dashcams and automotive accessories globally. Its operational footprint includes R&D, brand marketing, e-commerce operations, customer support and administrative functions.

The supply chain includes:

· Tier 1: contract manufacturers (EMS), original design manufacturers (ODM), assembly facilities and direct packaging suppliers.

· Tier 2 and beyond: component suppliers, including semiconductors, image sensors, lens assemblies and printed circuit boards, together with raw-material providers.

· Logistics and warehousing / fulfilment partners operating across the supply chain.

Vantrue recognises that modern slavery risks in electronics supply chains can be concentrated in component sourcing, manufacturing and assembly environments, recruitment and labour-broker arrangements, and logistics or warehousing activities.

· Relevant UK legal entity: Vantrue Ltd

· Whilst Vantrue Ltd did NOT meet the £36M annual turnover threshold for the Section 54 obligation, the group Company exceeded this figure and therefore this statement is produced voluntarily.

· Group entities covered by this statement: Shenzhen Sanjiang Lechuang Technology Co. Ltd.

· Financial year covered: January 2025 to December 2025

3. Policies in Relation to Modern Slavery

Vantrue's Modern Slavery Policy prohibits forced and compulsory labour, child labour, retention of passports or identity documents, recruitment fees charged to workers, and restrictions on freedom of movement. The policy also requires suppliers to comply with applicable anti-slavery requirements and Vantrue's Supplier Code of Conduct.

Vantrue's supplier requirements are incorporated into purchasing and service arrangements, with compliance with anti-slavery legislation stated as a mandatory condition of relevant contracts.

Relevant supporting policies and controls include the Supplier Code of Conduct, procurement and supplier onboarding controls, whistleblowing / reporting arrangements, corrective-action procedures and employee training.

Policy review during the reporting year:

· Supplier contracts

· Procurement guidelines

· HR Manual

4. Risk Assessment and Management

Vantrue's approach is risk-based. Prospective manufacturing partners are screened for labour compliance, corporate history and reliance on third-party labour agencies before being added to the approved vendor list. All direct suppliers are subject to review and, where appropriate, on-site audit, including any tier 2 component suppliers.

The following risks are specifically relevant to Vantrue's supply chain:

· Forced or compulsory labour in manufacturing and assembly facilities.

· Recruitment-related exploitation, including worker-paid recruitment fees or deposits.

· Retention or confiscation of passports, identity documents or work permits.

· Child labour and hazardous work involving workers under 18.

· Risks associated with labour brokers, recruitment agencies and other third-party labour providers.

· Risks further upstream in electronics components and raw-material supply chains.

Reporting-year risk assessment results to insert:

· Number / proportion of relevant suppliers assessed: Ten

· Number / proportion classified as high risk: NIL

· Countries / regions identified as higher risk: China

· Material modern slavery indicators identified: NIL

· Actions taken in response to identified risks: NONE REQUIRED

5. Due Diligence, Remediation and Supplier Management

Vantrue's due-diligence framework includes supplier onboarding screening, contractual requirements, Supplier Code of Conduct commitments, desktop reviews and on-site audits of all suppliers and higher risk Tier 2 suppliers. Reviews may consider working hours, wage payments, worker contracts, accommodation and other working-condition indicators.

Where evidence of modern slavery or severe labour non-compliance is identified, Vantrue requires corrective action. Failure to remedy serious breaches within the stipulated timeframe may result in termination of the business relationship and reporting to relevant authorities where required by law.

Vantrue will seek to respond to modern slavery concerns in a manner that prioritises the safety, rights and interests of affected workers. Where an incident is identified, the response should consider appropriate remediation, cooperation with relevant authorities and responsible engagement with the supplier, rather than automatically causing affected workers to lose employment.

Reporting-year due-diligence results to insert:

· Number of supplier screenings completed: Ten

· Number of desktop reviews completed: Ten

· Number of on-site audits completed: Six

· Number of corrective action plans issued: Nil

· Number of corrective action plans closed: Nil

· Supplier relationships terminated for modern-slavery / severe labour concerns: None.

· Worker remediation provided or facilitated: None.

6. Reporting Concerns and Protection from Retaliation

Vantrue encourages employees, supply-chain workers and business partners to report genuine concerns or suspicions of modern slavery, exploitation or human-rights violations without fear of retaliation.

Reporting channel: business@vantrue.com

Vantrue states that concerns raised in good faith will be treated confidentially and that individuals will not be subject to retaliation for making a genuine report.

Reporting-year data.  The number of relevant reports received, investigated and closed: NONE

7. Training and Awareness

Key personnel involved in global procurement, supply-chain operations, vendor management and human resources receive training on identifying indicators and red flags associated with modern slavery and forced labour.

Reporting-year training:

· Number of employees / relevant personnel trained: 32.

· Training completion rate: 100%.

· Functions / roles covered: Procurement, Vendor management, Contracts, Purchasing. HR.

· Training frequency: Every 6 months.

· Training effectiveness measures or assessment results: 100%

8. Monitoring, Effectiveness and Key Performance Indicators

Vantrue monitors the implementation of its anti-modern-slavery controls and reviews this policy annually. To demonstrate effectiveness and year-on-year progress, Vantrue will use appropriate indicators and retain supporting records.

9. Progress During the Reporting Year and Priorities

Progress achieved during the reporting year:

· All Modern Slavery reviews were conducted as scheduled, both in-house and at the Tier 1 and Tier 2 suppliers. The training for the principals of the Modern Slavery control requirements is delivered by the HR department who conduct training within Vantrue to the relevant applicable departments, twice a year.

· The training material addresses in-house staff and supplier review and is updated based upon feedback and experience of those staff delivering the material and conducting the reviews.

· KPI’s will continue to be monitored and the results reported with full transparency, in order to maintain the current good situation found at Vantrue and it’s supplier base.

Priorities for the next reporting year:

· Continued in-house and supplier review, as scheduled.

· Updated publication of the 2026 Statement.

· Targeted good choice of suppliers, in order to avoid corrective actions in future.

10. Governance, Approval and Publication

Responsibility for implementation of Vantrue's modern-slavery controls rests with relevant executive management, procurement, supply-chain, human-resources and legal/compliance functions. The policy and the effectiveness of relevant controls are reviewed annually.

Where this statement is published under section 54 of the Modern Slavery Act 2015, it will be approved by the board of directors, signed by a director, and published on Vantrue's website with a prominent link from the homepage.

· Vantrue Ltd Board approval date: 10^th June 2026

· Director: Jian Chen

· Date signed: 10^th June 2026.

· Website publication date: 25^th August 2026

· Statement URL: TBC

Director Approval and Sign-Off

Approved by the Board of Directors on: 10^th June 2026

Signed by: Jian Chen Director

Date: 10^th June 2026

Signature: ______________________________

11. Legal and Reporting Note

This statement has been prepared with reference to section 54 of the Modern Slavery Act 2015 and current Home Office guidance. It should be completed with accurate information for the relevant financial year and reviewed by Vantrue's legal / compliance team before publication. Publication should not imply that Vantrue guarantees that its entire supply chain is free from modern slavery; rather, the statement should accurately describe the steps actually taken to identify, prevent, mitigate and respond to relevant risks.

Vantrue Modern Slavery Policy