Modern Slavery Policy

Zero tolerance. No exceptions.

Modern Slavery Policy Statement
Replacing Humans LLC (operating as “Callin.io”)

I. Overview

This Modern Slavery Policy Statement (“Policy”) is made by Replacing Humans LLC (“Callin.io”, “we”, “us”, “our”) and applies to our business and our supply chain. This Policy is issued in alignment with Section 54 of the UK Modern Slavery Act 2015, the Australia Modern Slavery Act 2018, the California Transparency in Supply Chains Act, and similar legislation (together, the “Acts”), to the extent applicable.

We do not support, tolerate, or knowingly benefit from Modern Slavery in any form. This Policy summarizes steps taken during the financial year ending 31 December 2024 (“FY24”) to reduce the risk of Modern Slavery in our operations and supply chain.

II. Definitions

For purposes of this Policy:

“Affiliates” means any entity that Replacing Humans LLC controls or that is under common control with Replacing Humans LLC. “Control” means direct or indirect ownership of more than 50% of voting interests, or the power to direct management and affairs by contract or otherwise.

“Modern Slavery” means human trafficking, forced or compulsory labor, servitude, slavery, child labor (work performed by individuals below the legal minimum working age), and other forms of exploitation recognized as modern slavery under applicable laws.

III. Our Commitment

Callin.io’s leadership and teams are committed to operating ethically and with respect for human rights. We take a zero-tolerance approach to Modern Slavery and do not knowingly do business with organizations that tolerate or engage in Modern Slavery.

All employees, contractors, vendors, partners, and suppliers are expected to uphold these standards and report suspected or actual Modern Slavery concerns promptly.

IV. Our Business & Risk Assessment

Organizational Structure

Replacing Humans LLC operates Callin.io, a software platform providing AI voice agents for inbound and outbound communications. Our operations are carried out through employees and contractors and supported by third-party vendors.

Business Overview

Callin.io provides an AI voice agent platform and related services, which may include (without limitation) voice agent configuration, customer support, integrations, analytics, and professional services supporting customer deployments.

We do not manufacture physical goods. Our key third-party relationships typically relate to cloud infrastructure, telecommunications/voice vendors, software tools, and professional services.

Risk Assessment & Management

We evaluate Modern Slavery risk using factors such as geography, work type, supplier model (including subcontracting), and the nature of services provided. As a technology company relying primarily on skilled professional services and regulated providers, we assess our overall risk as low, while recognizing that risks can still exist—especially in extended subcontracting chains.

Potential risks and mitigation measures include:

Reduced visibility into subcontractor practices

• Contractual requirements on legal compliance and ethical labor practices

• Preference for reputable vendors with clear employment standards

• Enhanced diligence for vendors that rely heavily on subcontracting or offshore labor

  
  

Excessive working hours / coercive practices

• Contract clauses requiring compliance with wage-and-hour and labor laws

• Encouraging reasonable workloads and providing reporting channels

• Review of engagement terms for contractor agencies and staffing partners

  
  

Forced labor (deemed unlikely but taken seriously)

• Internal standards and supplier expectations prohibiting Modern Slavery

• Reporting mechanisms and investigation procedures

• Corrective action up to and including termination where confirmed

  
  

Oversight is maintained by leadership, with support from relevant business functions (e.g., legal/finance/security/operations), depending on company structure and needs.

V. Supply Chain Due Diligence

Our supply chain may include:

• Cloud hosting and infrastructure providers

• Telecommunications and voice/AI service providers

• Software and technology vendors

• Professional services (e.g., contractors, agencies, consultants)

• Business support services and workplace equipment suppliers

  
  

We apply a risk-based approach to onboarding and ongoing vendor management. Depending on the engagement, our due diligence may include:

• Screening vendors for legal/regulatory compliance

• Reviewing relevant policies (where available) and ethical sourcing practices

• Contractual obligations to comply with applicable laws and to prohibit Modern Slavery

• Additional diligence for higher-risk suppliers (e.g., extensive subcontracting, unclear labor model, higher-risk jurisdictions)

If we discover or reasonably suspect Modern Slavery involving a supplier or partner, we will investigate and take appropriate corrective actions, which may include remediation requirements, suspension, or termination of the relationship where Modern Slavery is confirmed.

VI. Internal Practices

To reduce risk in our own business, Callin.io seeks to ensure that:

• Workers are engaged voluntarily, with transparent terms

• Employees and contractors have written agreements consistent with applicable law

• We verify legal eligibility to work where required

• We promote professional development, health, and wellbeing

• We maintain channels to raise concerns without fear of retaliation

VII. Key Performance Indicators

We measure effectiveness through practices such as:

• Periodic review and updates of relevant policies

• Maintaining records of supplier onboarding and diligence steps performed

• Tracking acknowledgments and training completion where applicable

• Monitoring, documenting, and addressing concerns raised through reporting channels

• Reviewing diligence processes at least annually for effectiveness

VIII. Policies Addressing Ethical Conduct

Callin.io expects ethical conduct from employees and, where applicable, contractors and vendors. Violations of ethical standards may lead to disciplinary action up to and including termination of employment or contractual relationships.

We aim to maintain a respectful workplace free from harassment, intimidation, discrimination, retaliation, bullying, and threats of violence, and we expect our partners to uphold comparable standards.

IX. Additional Practices

Recruiting

We aim to ensure recruitment is fair, transparent, and voluntary:

• No worker should be charged recruitment fees to work with us

• We expect any Employer of Record (EOR), staffing partner, or recruiting agency to comply with labor laws and to prohibit Modern Slavery

• We investigate credible allegations relating to exploitation in hiring channels

Awareness / Training

We provide onboarding guidance and role-appropriate information to personnel who may interact with vendor onboarding, hiring, or operational oversight.

Responsible Use of Our Services

Because our platform can be used to communicate at scale, we prohibit use that facilitates illegal or abusive activity, including trafficking, exploitation, or child endangerment. We may suspend or terminate accounts that violate our policies and cooperate with lawful requests where required.

X. Reporting & Investigation

We maintain a mechanism for reporting concerns, including suspected Modern Slavery, and we prohibit retaliation against anyone who raises concerns in good faith or participates in an investigation.

Reports are assessed promptly and investigated as appropriate, with corrective actions taken where warranted, including termination of relationships if Modern Slavery is confirmed.

XI. Ongoing Review & Improvement

We review this Policy no less than annually and update it as needed to reflect changes in legislation, industry practices, and our business operations. Our ongoing goals include:

• Improving awareness of obligations among employees and relevant third parties

• Refining vendor diligence practices based on risk

• Enhancing KPIs to better measure prevention efforts

• Evaluating governance structures that support cross-functional oversight

  
  

XII. Approval

This Policy is approved by the Director of Replacing Humans LLC.

Signed for and on behalf of Replacing Humans LLC
Director: Vincenzo Piccolo