Modern Slavery Statement

Version 3.0. Effective 2 November 2026.

In short

We have zero tolerance for modern slavery, forced labour and human trafficking. We are not legally required to publish this statement. We do it because our marketplace depends on people, and the people who drive, crew and fly for our operators deserve to be treated fairly. This is a statement of our policy for the financial year ending 31 December 2026. It says what we do, and the steps we are adding. It does not claim more.

This summary is for convenience only. The numbered sections below set out the full statement.

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1. Why we publish this

1.1 Pickup Technology Limited, RC 9548096 ("Pickup"), publishes this statement voluntarily, as a statement of its policy for the financial year ending 31 December 2026. Section 54 of the UK Modern Slavery Act 2015 requires a statement only from commercial organisations that carry on business in the United Kingdom and have a total annual turnover of at least £36 million, the threshold set by the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015. Pickup does not meet that test, and no Nigerian law requires a statement of this kind.

1.2 It is written with regard to the Trafficking in Persons (Prohibition) Enforcement and Administration Act 2015, the Labour Act (Cap. L1, Laws of the Federation of Nigeria 2004), the protection against slavery, servitude and forced labour in the Constitution of the Federal Republic of Nigeria 1999, and the UK Modern Slavery Act 2015, because we serve Guests of every nationality, including Guests from the United Kingdom. It follows the structure the UK Act suggests for a statement: our structure and supply chain, our policies, our due diligence, where the risk is, how we measure progress, and training.

1.3 "Modern slavery" in this statement includes slavery, servitude, forced or compulsory labour, and human trafficking.

2. Our business and supply chain

2.1 Pickup is a technology marketplace for chauffeur driven cars, crewed boats and yachts, and private jet charter, operating in Lagos. We own no vehicles, vessels or aircraft and employ no chauffeurs, captains, crew or pilots. Trips are provided by independent licensed Operators.

2.2 Our own people. A small team based in Lagos, and contractors who build and maintain the Platform.

2.3 Operators. Independent registered companies that employ or engage chauffeurs, captains, crew and flight crew. This is where the main risk in our value chain sits.

2.4 Suppliers. Technology, payment, identity verification and professional service providers.

3. Where the risk is

3.1 We consider the highest risk to be in ground transport, where chauffeurs can face long hours, withheld wages or identity documents, recruitment fees, or debt tied to vehicles.

3.2 We consider risk lower among vessel crew and flight crew, who are certificated and supervised by sector regulators, though not absent.

3.3 We consider risk in our technology suppliers to be low but not nil, including in outsourced work such as data labelling and support.

3.4 We are also alert to our Platform being misused to move trafficked people, including by boat and by air.

4. Policies and controls in place

4.1 Registered companies only. Every Operator has verified CAC registration, a TIN, verified directors and a corporate bank account in its own name. Payouts go only to that account.

4.2 Individual verification. Every chauffeur is verified in their own right, with their own account, NIN and live facial verification, FRSC driving licence and the Operator's confirmation that the chauffeur works for it; Pickup may add the LASDRI card, driver's badge and LASRRA card as requirements on at least 30 days' notice to Operators. Boat and aircraft crew are licensed through the Operator's regulator. Each chauffeur and crew member personally accepts the Crew Terms and reads the Privacy Policy when they join.

4.3 Operator obligations. The Operator Agreement makes each Operator solely responsible for lawful engagement, pay and working conditions of its personnel, and for compliance with employment and labour law. Operators control hiring, pay, shifts and whether to accept trips.

4.4 Fair labour clause. The fair labour clause in the Operator Agreement prohibits forced, compulsory or trafficked labour, retention of personnel's passports, identity documents or licences, recruitment or placement fees charged to workers, and pay below the legal minimum. It requires Operators to let crew raise concerns with Pickup directly and prohibits retaliation. Breach is a material breach that cannot be remedied and leads to removal.

4.5 Fitness for duty. The Operator Standards require assigned crew to be rested and fit for duty, and long car days are scheduled with breaks within the legal driving limits.

4.6 No off platform payment. All payments go through Flutterwave, a licensed payment provider, which leaves a record and supports anti money laundering checks.

4.7 Passenger checks. The Booker, or for a car or boat a Lead Traveller who is on Pickup, completes an identity check before the trip. For jets, every passenger is named on a manifest before departure, and the Operator approves it. A passenger not on the manifest cannot board.

4.8 Safety reporting. Guests, Travellers and personnel can report concerns in the app.

4.9 Direct reporting for crew. The Crew Terms tell chauffeurs and crew that they can report concerns about their treatment to Pickup directly at legal@pickupltd.com, without going through their Operator, and prohibit retaliation.

5. Due diligence and the steps we are adding

5.1 A confidential reporting channel for crew. We plan to add a confidential reporting option to the crew app, alongside the email route in clause 4.9, which is open now. Reports go to our trust and safety lead, who decides on next steps and escalates to a director where a report suggests modern slavery.

5.2 Guidance and referral procedure. We plan for our trust and safety team to adopt written guidance on the signs of trafficking and forced labour in transport, and a procedure for referring cases to the National Agency for the Prohibition of Trafficking in Persons (NAPTIP) and the Nigeria Police Force.

5.3 Supplier questions. Our policy is to ask material suppliers (technology, payment, verification and outsourced support providers) questions on labour practices at onboarding, and to require them by contract to comply with anti slavery and labour laws.

5.4 Signals we act on. A report from crew, a Guest's report, an Operator that cannot show who its chauffeurs are, the same identity documents used for different people, or a pattern of trips that suggests people are being moved against their will, leads to a review by a person.

6. Training

6.1 Our policy is that everyone in our trust and safety, support and operator onboarding teams completes training on recognising and reporting modern slavery when they join and every year after that.

6.2 Our policy is that Operators receive guidance on their fair labour obligations under the Operator Agreement during onboarding.

7. Responding to concerns

7.1 If we find or suspect modern slavery involving an Operator, we suspend the Operator, protect the people affected as far as we can, and report to the relevant authorities. We do not punish a worker for reporting, and we do not share a reporter's identity with their Operator without their consent unless the law requires it.

7.2 Report a concern to legal@pickupltd.com. You do not need to give your name. In an emergency, call 112.

8. Measuring progress

8.1 Each statement reports against these measures for the year before:

• whether each action in section 5 has been completed, and when;
• the proportion of trust and safety, support and onboarding staff who completed training in the year;
• the number of concerns about treatment of personnel raised, by route, and how each was handled;
• the number of Operators suspended or removed for breach of the fair labour clause of the Operator Agreement; and
• the proportion of material suppliers who answered the labour practice questions.

9. Review

9.1 This statement is made by Pickup Technology Limited as a statement of its policy for the financial year ending 31 December 2026.

9.2 We review and republish it every year, within six months of the end of each financial year.