COMPLIANCE

Commitment to Preventing Trafficking in Persons

Railo Technology is committed to preventing trafficking in persons and fully complies with the U.S. Government’s zero‑tolerance policy under FAR 52.222‑50. We strictly prohibit human trafficking, commercial sex acts, forced labour, withholding or destroying identity documents, misleading or deceptive recruitment, charging recruitment fees, and providing housing that does not meet host‑country standards. Our employees are provided with clear written employment terms in a language they understand, and wages meet applicable legal requirements.

We maintain internal instructions and awareness measures to ensure that all personnel understand prohibited practices and their obligations to uphold these standards. Employees, subcontractors, and agents can report concerns confidentially and without fear of retaliation through Railo Technology’s Whistleblowing Channel.

Railo Technology ensures that recruitment is conducted only through trained and compliant partners, that no improper fees are charged, and that any provided housing is safe and legally compliant. We monitor our subcontractors and agents to prevent, detect, and address any trafficking‑related risks. If violations occur, we take immediate corrective action, which may include removing personnel, terminating contracts, cooperating with authorities, and protecting any affected individuals.

This statement represents the relevant contents of Railo Technology’s Trafficking in Persons compliance plan as required to be posted on our website under FAR 52.222‑50(h)(4).

Whistleblowing channel

Railotech´s whistleblowing channel offers our employees, former or temporary workers, interns, job seekers, voluntary workers, contractors, subcontractors, customers, members of the board and shareholders a confidential channel to report any suspected misconduct or non-compliant behaviour.

Notifications may concern the information received in connection with work performed for Railotech. Whistleblowers who report a violation of the regulations are covered by the Whistleblower Protection Act. A notification can be filed based on suspension and without actual evidence, as long as it is made honestly and in good faith.

The whistleblowing channel has been implemented in such a way that the notifications can be sent completely anonymously. All notifications are treated confidentially and with privacy protection. A case will not be investigated by anyone who may be involved in or connected to the reported wrongdoing.

We will acknowledge receipt of your notification within 7 days, and further information may be requested during the investigation. All dialogue will take place through the whistleblowing channel and the notifier will see only the open dialogue, not the original notification in full. We will inform you of the outcome of the investigation via the First Whistle channel within 3 months of the notification.