MODERN SLAVERY & HUMAN TRAFFICKING STATEMENT

Effective Date March 2026

1. Introduction

peakleap GmbH is a people development company dedicated to driving growth and sustained success in law and consulting firms. We deliver practical strategies through structured programmes and operate FITI PRM, an AI-driven personal relationship management SaaS tool for legal and consulting professionals.

This statement sets out peakleap GmbH's position on modern slavery and human trafficking. It is published voluntarily – peakleap falls below the turnover thresholds of both the UK Modern Slavery Act 2015 and the German Lieferkettensorgfaltspflichtengesetz (LkSG) and is not legally required to publish such a statement. We do so because we believe transparency on these issues is the right thing to do, and because the law and consulting firms we serve hold their suppliers to high ethical standards.

Legal basis: UK Modern Slavery Act 2015; LkSG (Lieferkettensorgfaltspflichtengesetz); ILO Forced Labour Convention No. 29

2. Our Business & Supply Chain

peakleap GmbH employs 7 people across full-time and Minijob roles and operates on a hybrid model from our registered office in Inning am Ammersee, Germany. Our work is knowledge-based – we deliver consulting programmes, coaching, and a digital SaaS product. We do not manufacture physical products, operate production facilities, or engage with complex multi-tier supply chains.

Our supply chain consists primarily of two categories:

Enterprise technology and cloud infrastructure providers – including Microsoft, GitHub, Supabase, Vercel, Stripe, GoDaddy, and others. These are major global organisations with their own published modern slavery and ethical trading commitments and enterprise-level compliance programmes.
Individual freelancers and contractors – engaged directly for specific technical or programme delivery work, on documented individual contracts.

Given this profile, peakleap's exposure to modern slavery and human trafficking risk in its supply chain is assessed as low. Nevertheless, we take this assessment seriously and review it as our business grows.

3. Our Commitment

peakleap GmbH has a zero-tolerance position on modern slavery, forced labour, child labour, and human trafficking in all forms – within our own business and across our supply chain. We are committed to acting ethically and with integrity in all our business relationships.

Specifically, peakleap commits to:

Never knowingly engaging with any supplier, contractor, or business partner involved in modern slavery or human trafficking
Treating all personnel with dignity and respect, paying at least the applicable minimum wage, and ensuring all working arrangements are freely chosen
Ensuring that no member of peakleap's team works under conditions of coercion, threat, or exploitation
Maintaining open reporting channels so that any concern can be raised safely and without fear of retaliation
Reviewing and strengthening our approach as the business and its supply chain evolve

4. Company Standards for Employees & Contractors

peakleap's commitment to ethical conduct is embedded across its policy framework. All employees and contractors are required to comply with:

peakleap's Code of Conduct – which prohibits exploitation, coercion, harassment, and any conduct inconsistent with human dignity, and applies to all employees, contractors, and third parties acting on peakleap's behalf
peakleap's Anti-Bribery & Ethical Trading Policy – which sets standards for ethical business conduct, prohibits corrupt practices, and requires third parties to meet equivalent ethical standards

Contractor agreements are currently being updated to include explicit modern slavery and human trafficking clauses, requiring contractors to confirm compliance with applicable anti-slavery laws and to notify peakleap of any concerns in their own operations.

Legal basis: peakleap Code of Conduct (March 2026); peakleap Anti-Bribery & Ethical Trading Policy (March 2026)

5. Consequences of Non-Compliance

Any breach of this statement or peakleap's related policies by an employee, contractor, or supplier will be treated as a serious matter. Depending on the nature and severity of the breach, consequences may include:

Immediate termination of employment or engagement
Termination of the supplier or contractor relationship
Referral to competent authorities, including the Staatsanwaltschaft (public prosecutor) or relevant law enforcement

No employee or contractor will face retaliation for raising a genuine concern about modern slavery or human trafficking in good faith.

Legal basis: StGB §§ 232–233b (Menschenhandel); HinSchG (Hinweisgeberschutzgesetz)

6. Supply Chain Due Diligence

peakleap monitors modern slavery and human trafficking risk in its supply chain through the following measures:

Enterprise technology providers are selected in part on the basis of their published compliance standards, which include modern slavery and human rights commitments. peakleap relies on each provider's own published due diligence programmes, which are subject to enterprise-level scrutiny.
Individual freelancers and contractors are engaged directly by the Managing Director, without use of third-party recruitment agencies or labour intermediaries – eliminating the primary channel through which recruitment-related modern slavery risk typically arises.
New supplier and contractor relationships are subject to a basic review of ethical conduct standards before engagement commences.

peakleap does not currently work with a specialist third-party organisation to assess supply chain slavery risk, consistent with the firm's size and low-risk supply chain profile. This will be reviewed as peakleap's operations scale.

7. Training & Awareness

All peakleap employees and contractors are briefed on the Code of Conduct and Anti-Bribery & Ethical Trading Policy upon joining, which includes awareness of ethical conduct standards relevant to exploitation and coercion. Specific modern slavery and human trafficking awareness will be incorporated into onboarding briefings as part of this statement's rollout.

Given peakleap's size, awareness is maintained through direct engagement between the Managing Director and all team members rather than a formal training programme. As the team grows, dedicated modern slavery awareness will be introduced.

8. UN Global Compact Principles

peakleap GmbH conducts its business in a manner consistent with the intent of the UN Global Compact Ten Principles across all four pillars – human rights, labour standards, environmental responsibility, and anti-corruption. In particular:

Principle 1: We support and respect the protection of internationally proclaimed human rights within our sphere of influence
Principle 2: We ensure we are not complicit in human rights abuses
Principle 3: We uphold freedom of association and recognise the right to collective bargaining
Principle 4: We support the elimination of all forms of forced and compulsory labour
Principle 5: We support the effective abolition of child labour
Principle 6: We support the elimination of discrimination in employment and occupation

peakleap has not formally registered as a UN Global Compact signatory at this time. Formal adoption is under active consideration as part of peakleap's commitment to responsible business practices.

9. Reporting Concerns

Anyone who suspects modern slavery, forced labour, or human trafficking in connection with peakleap's business or supply chain is encouraged to report this immediately. Reports can be made to:

Contact	Anja Kreutzahler, Managing Director
Email	[email protected]
How	In person, by email, or in writing

All reports will be taken seriously, investigated promptly, and treated in confidence. peakleap will not retaliate against anyone raising a concern in good faith. Employees are additionally protected under the Hinweisgeberschutzgesetz (HinSchG) and EU Directive 2019/1937.

Legal basis: HinSchG; EU Whistleblowing Directive 2019/1937

10. Review & Continuous Improvement

This statement is reviewed annually by the Managing Director. It will be updated to reflect changes in peakleap's business operations, supply chain, and applicable legal requirements. Future iterations will incorporate measurable targets and more structured due diligence processes as the firm grows.

Annual review: March each year
Triggered review: following any material change in business model, supply chain, or personnel
All team members may raise concerns or suggestions at any time