This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps Darktrace plc, on behalf of itself and its wholly-owned subsidiary Darktrace Holdings Limited (together with the subsidiaries of Darktrace Holdings Limited, the “Darktrace Group”) has taken during the fiscal year ended 30^th June 2021 (“FY 2020-21”) and will continue to take to ensure that modern slavery or human trafficking is prevented.

The Darktrace Group applies a zero-tolerance approach to any form of modern slavery. We are committed to acting with transparency in all business dealings, preventing modern slavery taking place within our business or supply chains.

Darktrace plc is a public listed company, trading on the London Stock Exchange main market for listed securities under the ticker DARK. Darktrace plc is registered under the laws of England and Wales. Its wholly-owned subsidiary Darktrace Holdings Limited is a private limited company registered in England and Wales. Taken as a whole, the Darktrace Group is a global cyber security company, and during FY 2020-21, maintained approximately 44 offices worldwide.

Given the nature of the Darktrace Group’s business, we believe there is a very low risk that modern slavery and human trafficking would be present in our supply chains or affect our business.

Our main business is the research, development, and sales of cyber security software. We provide our proprietary software to thousands of customers in the United Kingdom and around the world. Our customers span enterprises of all sectors and sizes. We sell our software to customers directly as well as through a robust channel of resale partners. While not part of our supply chain, we nevertheless expect members of our channel to adhere to our ethical standards, as discussed more below.

We primarily deliver our software to customers through two avenues: by hosting instances of our software in the cloud, or by utilizing hardware appliances, on which our software comes pre-installed. For hosting services, we utilise industry-standard providers, namely Microsoft Azure and Amazon Web Services. Our hardware is sourced from reputable suppliers in the United Kingdom and Ireland, with whom we have longstanding relationships; the hardware is manufactured in the United Kingdom or the Czech Republic. Additional details concerning our supplier relationships are provided in section 4, under Due Diligence, Assessment of Modern Slavery Risk & Supplier Commitments, below.

The development of our software is conducted entirely in-house by our employees. Sales activities are similarly conducted by our employees, who are based out of our offices worldwide.

The vast majority of our workforce are full-time employees who are office-based and employed either by Darktrace Holdings Limited or one of its wholly-owned subsidiaries in the relevant territory. However, given the ongoing COVID-19 pandemic, which continued throughout the entire duration of FY 2020-21, members our workforce have either performed their duties entirely from home or been on hybrid models where they spent a few days per week in an office. Our guidance has varied by territory and been in compliance with local COVID-19 lockdown restrictions.

Our human resources team managed the hiring of staff as well as taking responsibility for their well-being and the Darktrace Group’s compliance with applicable labour laws wherever they were working.

The Darktrace Group maintains a number of internal policies and procedures throughout the business, reflecting our commitments to our ethical standards and acting with integrity and transparency in our business relationships. These policies are made available on our internal Intranet site to all employees, and to customers upon their request. The Darktrace Group periodically reviews and updates our policies to reflect evolving industry norms and best practices.

• Anti-Slavery Policy. This policy sets out our stance on modern slavery and ensures all relevant staff are alert to the risk of slavery and human trafficking occurring in our business or supply chains.
• Whistleblowing Policy. We enforce a whistleblowing policy to provide protection to all employees who wish to fairly raise concerns either about how colleagues are being treated, or practices within our business or supply chains, without fear of retaliation. Since the end of the FY 2020-21 fiscal year, the Darktrace Group has engaged a third-party provider to implement an anonymous whistleblowing service, which is now available in all our operating countries.
• Code of Business Conduct. The Darktrace Group has a Code of Business Conduct setting forth our ethical standards. We expect our employees, as well as our suppliers and partners, to comply with the standards detailed therein.
• Employee Handbook. We make clear to all employees the actions and behaviour expected of them when representing the organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating our business. Our Employee Handbooks detail the consequences for failing to meet these standards, which may include termination.
• Recruitment Policy. Our HR team operates a robust recruitment policy, ensuring that we comply with all applicable laws in the territories where we operate. In order to safeguard against modern slavery, only reputable employment agencies are sourced to recruit our employees. We have a zero-tolerance approach to the imposition of any financial burdens on prospective employees, such as requiring candidates to pay recruitment fees.

All employees are required to review and acknowledge these policies and certain topics are the subject of mandatory compliance trainings such as Preventing Workplace Harassment. During the coming fiscal year the Darktrace Group plans to develop and require our staff to complete additional trainings on the above policies.

As discussed below, the Darktrace Group has also implemented various controls including a country grading scheme to better assess risks in various territories around the world. Our staff are advised and trained to take particular care with organisations that provide services from higher risk territories. Staff are also advised to notify the Darktrace Group Legal and HR teams immediately if they have any concerns that modern slavery is taking place within the business or supply chain, so that appropriate action can be taken.

Our process for contracting with suppliers includes checks to remain vigilant to any risk of modern slavery and human trafficking. These may include (but are not limited to):

• Due Diligence, Assessment of Modern Slavery Risk & Supplier Commitments. It is a requirement that staff engaged in the process of selecting suppliers or resale or other partners conduct reasonable checks to ensure that suppliers or partners are held to account over modern slavery. We may also require the suppliers/partners to provide a copy of relevant policies and their employee handbook, both to confirm their policies require onward obligations on the part of their suppliers and to confirm their policies are at least equivalent to the Darktrace Group’s policies.
• As mentioned above, the Darktrace Group has recently implemented a country grading scheme, which will take into account the scoring provided by the Global Slavery Index in assessing such risks. We anticipate revising our risk assessment process in the upcoming fiscal year and conducting additional risk-mapping exercises in our supply chain. In connection with that process, we are considering engaging an external auditor to conduct audits of our suppliers and ensure their compliance with measures to prevent modern slavery, including where necessary, verification of the working conditions of suppliers’ staff and contractors.
• Contractual Commitments. The Darktrace Group believes we have appropriate protections in our agreements with suppliers. Where necessary, there is a written requirement for suppliers to implement effective systems and controls to prevent slavery from affecting any part of the business/supply chain. We can also require our suppliers to provide us with a summary of the steps they take to prevent modern slavery, including details of any relevant policies applicable to their staff and their suppliers.
• Termination. We also reserve the right to terminate a contract at any time should any instances of modern slavery come to light.

No reports from employees, the public, or law enforcement agencies have been identified to indicate that modern slavery practices are taking place within our business or supply chains. We are continually committed to keeping this policy current and relevant. This statement will be monitored and reviewed annually.

This statement was approved by the Board of Darktrace plc on 24^th November 2021.