Modern Slavery Statement

Modern Slavery and Human Trafficking Statement

For the Financial Year Ending December 2026

Altenar

This statement is made pursuant to Section 54(1) of the U.K. Modern Slavery Act 2015 and sets out the steps that Altenar has taken, and is continuing to take, to ensure that modern slavery or human trafficking is not taking place within its operations, business, or supply chains.

1. Our Business and Structure

Altenar is an industry-leading sportsbook software provider, serving licensed business-to-consumer gaming operators with over 700 employees across several offices in Europe, Africa, Asia, and the Americas.

2. Supply Chain

Altenar’s business model requires long-term relationships with suppliers and customers based on stability and flexibility, and relies primarily on data inputs and technological services to provide its services. Altenar’s chief input is sports event data, which it receives from a broad network of reputable providers within the sports betting industry that are subject to the high level of scrutiny and regulation applicable to the sports betting industry. The risk of modern slavery and human trafficking is further mitigated by these providers operating in jurisdictions with strong legal frameworks.

Within its wider supply chain, Altenar procures services from data centers and hardware providers, as well as ancillary goods and services such as cleaning services and office supplies.

3. Our Commitment

As a business operating within the regulated gaming sector, Altenar is committed to conducting its activities responsibly, respecting internationally recognized human rights, and acting ethically and with integrity across all business relationships. To support this, the business has implemented procedures to ensure modern slavery is not taking place anywhere within its own operations or supply chains.

4. Policies and Governance

Within the employment policy framework, Altenar has implemented the following policies and procedures to support this commitment:

● Modern Slavery and Human Trafficking Policy – outlines our approach to preventing and
responding to modern slavery.

● Code of Conduct – sets clear expectations for employee behavior and ethical standards.

● Whistleblowing Policy – provides a safe and confidential way for staff and stakeholders to raise concerns.

These policies are periodically reviewed to ensure they remain appropriate, effective, and aligned with applicable legal and regulatory requirements.

5. Due Diligence and Risk Assessment

Altenar conducts due diligence when engaging new suppliers and periodically reviews existing relationships to ensure compliance with its standards. Should a material modern slavery risk or concern be identified, the company will seek to understand the circumstances and determine suitable risk-mitigation measures.

Within the business risk assessment process, Altenar will conduct a review of its exposure to modern slavery and human trafficking risks within its operations and supply chain. Given the software-as-a-service nature of its business, the locations from which these services are provided, the nature of the suppliers Altenar engages, and the type of customers Altenar serves, the risk of modern slavery and human trafficking has been assessed as low.

Altenar continually assesses the risk it faces, and any substantial strategic change leading to increased risks of slavery and human trafficking will be assessed and, where appropriate, controls will be adapted to mitigate such risks.

6. Training and Awareness

Upon commencement of employment with Altenar, training and documentation are provided to help employees understand the underlying principles, objectives, and practical implications of the Altenar Code of Conduct, and to promote awareness of ethical business conduct.

7. Looking Ahead

In the coming year, Altenar aims to further refine its supplier due diligence processes, optimize the periodic review process for supplier relationships, continue raising awareness around the risks of modern slavery and human trafficking, and deliver training to its workforce.

Altenar remains committed to reviewing its policies and internal processes to strengthen its approach to identifying, assessing, and managing modern slavery risks, while further embedding ethical business practices across its operations and supply chain.

8. Board Approval

The statement was approved by the Board of Directors of Altenar Technologies Limited and signed on its behalf by Natalie Campbell, Director, on August 11, 2026.