Modern slavery act transparency statement

This ICEYE’s Modern Slavery Act transparency statement (the “Statement”) is made in accordance with Section 54 of the UK’s Modern Slavery Act 2015. As this is the first year ICEYE is making this Statement, ICEYE will not be including a report comparing the steps taken to previous years.

ICEYE has zero tolerance towards any form of modern slavery. Slavery, forced or compulsory labor, child labor, servitude, and human trafficking are global and growing issues to which no business or industry is immune. ICEYE is committed to social and environmental responsibility and is taking steps to ensure that slavery and human trafficking are not taking place in any part of our own business or in our supply chain.

Our business

ICEYE manufactures and operates the world's leading radar satellite constellation, which provides access to timely and reliable satellite imagery. We deeply care about the environment and the society of which we are a part. ICEYE’s radar satellite imaging service and hardware help clients resolve challenges in sectors such as maritime, disaster management, insurance, finance, security, and intelligence. Our constellation of SAR (synthetic aperture radar) satellites enables a high level of change detection both day and night and in any weather.

In addition to radar satellite imaging itself, we are building industry-specific information services to address sustainability issues as well as environmental problems and monitoring natural catastrophes. Our constellations’ ability to revisit the same location in space even sub-daily, enables us to provide near real-time data across the globe. We can participate in solving, for example, climate change related or other sustainability issues by providing imagery and solutions to monitor and address illegal fishing, maritime traffic, floods, or wildfires.

ICEYE Oy, the parent company, has its headquarters in Espoo, Finland, and has six subsidiaries, in the UK, Poland, Luxembourg, Spain and in the US.

Our operations in the UK

The focus of ICEYE operations in the UK is commercial sales and sales operations management. ICEYE has no manufacturing or supply chain management functions in the UK.

Human rights and ICEYE code of conduct

ICEYE is committed to respecting internationally recognized human rights and continuously develops its operations in alignment with the UN Guiding Principles on Business and Human Rights (UNGP). We respect ILO Labor Standards and acknowledge the UN Sustainable Development Goals (SDGs) and work to develop our operations in close link to them.

ICEYE’s Code of Conduct, published in March 2023, sets the minimum requirements applied with respect to our employees and ICEYE as an organization. As we have a culture of acting as one, we must always respect each other and interact in a good and polite manner. We do not tolerate any kind of inappropriate behavior or discrimination based on race, religion, gender, political opinion, age, nationality, sexual orientation, civil status, or disability. Everyone is seen and valued as an individual, and we promote and respect everyone's freedom to express their thoughts, opinions, and religion.

We have zero tolerance towards mistreatment, abuse, bullying, sexual harassment, or any kind of personal offensive behavior. Those who violate the code are subject to appropriate disciplinary actions. We strongly advise our employees to report any inappropriate behavior.

We are setting up regular training for our personnel on the key contents of our Code of Conduct. ICEYE’s Whistleblowing Channel is open for our employees, to raise concerns on unethical conduct, including potential human rights violations.

ICEYE Supplier Code of Conduct will be published in due course after the ICEYE Code of Conduct. The Supplier Code of Conduct will set the minimum requirements for our suppliers in terms of compliance with applicable legislation, ethical business, and sustainability. In this Supplier Code of Conduct, human rights, including the prohibition of modern slavery, are increasingly emphasized and several related topics will be added as requirements for our suppliers.

ICEYE supply chain

Sourcing is a key activity in the optimization of ICEYE’s supply chain and has a direct impact on the company’s success. Sourcing and procurement activities reside within ICEYE’s Supply Chain organization. ICEYE’s Supply Chain organization has the overall responsibility for purchasing, for both operational and strategic, activities in ICEYE, globally.

ICEYE Supply Chain acknowledges the dynamic nature of the market, hence proactively scans for alternative sources, follows the market development and trends, and conducts supplier evaluations and comparisons. Suppliers are measured regularly with key performance indicators and results are used for decision making.

ICEYE’s Global Supply Chain organization is committed to following all local and international rules and regulations. All members of the team are required to work honestly, reliably, and professionally. Only just and fair negotiation tactics are allowed.

We take steps to ensure that modern slavery is not taking place in our global supply chain. ICEYE Supply Chain respects and supports all human rights and condemns any discrimination. ICEYE will not collaborate with any supplier or any party whatsoever, that uses child- or forced labor or operates in conflict areas. No parts or materials ICEYE uses shall be produced by child- or forced labor.

We continuously assess and aim to develop our methods of detecting human rights impacts in our own operations and in our supply chain. ICEYE is committed to investigating and applying appropriate remedial actions with respect to any suspected Modern Slavery related violation. We understand that modern slavery risk is a matter that requires constant effort and risk mitigation activities and continuous training will be required going forward.

This Statement has been approved by the Board of Directors of ICEYE Oy and constitutes the Modern Slavery Act transparency statement for the relevant group companies. This Statement will be published annually.