Modern Slavery and Human Trafficking Statement

Introduction

Rotron Aerospace Ltd is committed to conducting business with integrity and transparency. We maintain a zero-tolerance approach to modern slavery and human trafficking across our operations and supply chains. This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and outlines the steps taken during the financial year ending 2026 to prevent such practices.

As part of the Ondas Holdings Inc. group, Rotron Aerospace supports the highest standards of ethical conduct within the global defence and aerospace sector.

1. Organisation and Business

Rotron Aerospace Ltd is a UK-based aerospace engineering and manufacturing company specialising in propulsion systems and unmanned aerial technologies for defence and industrial applications. The company operates as part of Ondas Holdings Inc., a US-listed organisation focused on autonomous systems and critical communications technologies.

2. Our Supply Chains

Our supply chain includes:

• Aerospace-grade materials
• Precision manufacturing and machining
• Electronics and propulsion systems
• Subcontracted fabrication and assembly
• Testing and certification services

Suppliers are primarily located in the United Kingdom, United States, and other allied industrial jurisdictions. We work closely with our partners to ensure ethical and responsible sourcing throughout all tiers of the supply chain.

3. Policy Framework

Rotron Aerospace maintains a comprehensive governance framework to prevent modern slavery and human trafficking. Key policies include:

• Code of Business Conduct and Ethics
• Supplier Code of Conduct
• Whistleblowing Procedures
• Anti-Bribery and Corruption Policy
• Procurement Compliance Standards

These policies reinforce our commitment to ethical business practices and responsible supplier relationships.

4. Due Diligence Processes

We apply a risk-based due diligence approach to supplier management, including:

• Supplier onboarding and background checks
• Contractual clauses requiring compliance with modern slavery legislation
• Risk assessments based on geography and labour practices
• Escalation and remediation procedures where concerns are identified

Enhanced scrutiny is applied to suppliers operating in higher-risk regions or where subcontracted labour is involved.

5. Defence-Sector Risk Management

Given the complexity of aerospace and defence supply chains, Rotron Aerospace implements layered risk controls to ensure transparency and accountability. These include:

• Traceability requirements for critical components
• Supplier audits where appropriate
• Ongoing compliance monitoring
• Alignment with industry best practices and regulatory expectations

6. Training and Awareness

Relevant personnel within procurement, operations, and compliance functions receive training to help identify and mitigate the risks of modern slavery and human trafficking. This training ensures that employees understand their responsibilities and can report concerns effectively.

7. Measuring Effectiveness

To assess the effectiveness of our actions, Rotron Aerospace:

• Reviews supplier compliance and performance
• Monitors and investigates reported concerns
• Continuously enhances governance and risk management frameworks
• Updates policies and procedures in line with evolving best practices

8. Approval and Review

This statement has been approved by the Board of Directors of Rotron Aerospace Ltd and will be reviewed and updated on an annual basis.

Signed: Alex Head
Director
Date: 16 March 2026

Appendix A – Supplier Code of Conduct (Summary)

Rotron Aerospace expects all suppliers to adhere to the following principles:

1. Compliance with Laws
   Suppliers must comply with all applicable labour, human rights, and modern slavery legislation.
2. Prohibition of Forced Labour
   All forms of forced, bonded, or involuntary labour are strictly prohibited.
3. Child Labour
   Suppliers must not employ child labour and must adhere to internationally recognised standards.
4. Working Conditions
   Safe, fair, and humane working environments must be provided.
5. Wages and Benefits
   Workers must receive wages and benefits that meet or exceed legal requirements.
6. Subcontracting Transparency
   Suppliers must ensure that subcontracting does not conceal labour violations and that transparency is maintained across all tiers.
7. Right to Audit
   Rotron Aerospace reserves the right to request evidence of compliance or conduct audits where risks are identified.
8. Reporting Concerns
   Suppliers must provide mechanisms for workers to report concerns without fear of retaliation.

Download the Statement

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