Modern Slavery Act - Transparency Statement

Introduction

This statement sets out the steps and measures that Noldus Information Technology (“Noldus”) has taken and is continuing to take to ensure that modern slavery is not taking place within our business or first line supply chain. Modern slavery encompasses slavery, servitude, human trafficking and forced labor. Noldus has a zero-tolerance approach to any form of modern slavery and we are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or supply chain.

Our organization

Noldus is an innovative product developer providing software, hardware and integrated solutions for animal and human behavior research, addressing important societal challenges. We help our customers improve their research, inspired by scientific and societal challenges. Our technologies and tools are designed to enhance health and wellbeing, and to contribute to sustainable development and quality of life. We are headquartered in Wageningen, The Netherlands, but act globally via our own offices and representatives, and our products and services are sold and marketed through a well-developed collaboration with and network of distributors, system integrators and resellers.

Our code of conduct

Noldus is committed to conducting business in an honest, fair and transparent way. Noldus adheres to the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights. These provide principles and standards for responsible business conduct in a global context consistent with applicable laws and internationally recognized standards. These publications are multilaterally agreed and comprehensive codes of responsible business conduct that governments have committed to promoting.

The Noldus Code of Conduct defines the values and guidelines upon which Noldus conducts its business. The Code of Conduct applies to everyone who works for Noldus worldwide and to anyone representing Noldus in any way. We also expect our business partners, including any subcontractors they engage with in relation to their business with Noldus, to comply with this Code of Conduct. The Code of Conduct is based on the UN Global Compact’s ten principles, the UN Declaration of Human Rights and the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work. The company management ensures that business is conducted in an ethical way and in accordance with the Code of Conduct and the company’s policies are continually reviewed. In addition to the Code of Conduct, Noldus operates a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

Risks

Noldus considers the issues and risks covered by the UK Modern Slavery Act, and even if we deem them to be non-existent within our own operations, we are well aware that the risks are higher in our supply chains. Noldus therefore undertakes extensive work in the selection of suppliers as well as following up supplier compliance with audits.

Our suppliers

Suppliers are classified based on risk level, taking into account the country in which the supplier conducts its business, credibility and previous evaluations (if such exist). We are committed to ensure that modern forms of slavery are absent in our supply chains. We carefully select our suppliers for manufacturing and assembly of the company’s products. The selection takes into account employee working conditions such as freedom to join a trade union, business ethics, and respect for human rights. All new suppliers are initially evaluated before collaboration is initiated.

Suppliers are also expected to comply with the Noldus Supplier Code of Conduct, which is based on the Noldus Code of Conduct and the UN Global Compact 10 principles in the areas of human rights, labor, environment and anti-corruption. This includes requirements prohibiting any form of child or compulsory/forced labor and ensuring good working conditions. Noldus expects the supplier to use reasonable efforts to promote compliance with the Noldus Supplier Code of Conduct among its suppliers. Audits of critical suppliers are carried out throughout the contract time. The supplier audits aim to follow up and ensure that suppliers meet the requirements in the Supplier Code of Conduct. The Supplier Assessment form checks, for instance, whether suppliers published a modern slavery/human trafficking statement on their website. If it should become apparent that a supplier does not meet Noldus requirements, the supplier will be phased out if it does not implement corrective actions.

Training

All employees must comply with Noldus Code of Conduct and the corporate culture and values are important parts of the onboarding program for new employees as well as in other training and employee programs.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that modern slavery is not taking place within our business or supply chain if no reports are received from (a) the employees of Noldus who work dedicatedly to uphold Noldus core values and Code of Conduct, or (b) the public or law enforcement agencies to indicate that modern slavery practices have been identified. Furthermore, the audits we conduct and on-premise visits at our suppliers also serve as performance indicators in relation to our Code of Conduct.

Approval for this statement

This statement was approved by the Executive Board of Noldus Information Technology on April 29, 2025.

Jay de Groot - Noldus Information Technology