Modern Slavery and Human Trafficking Statement

For the financial year ending 31 December 2024
Published pursuant to Section 54 of the UK Modern Slavery Act 2015

Background

This statement is made on behalf of WirelessCar Sweden AB and its affiliated entities (collectively, “WirelessCar”) in accordance with Section 54 of the United Kingdom Modern Slavery Act 2015. It sets out the steps taken during the financial year to prevent modern slavery and human trafficking in our business operations and supply chains.

WirelessCar acknowledges the importance of upholding human rights in a globalized economy. Through our parent company, the Volkswagen Group, we have affirmed our commitment to internationally recognized human rights frameworks, including the Declaration by the Volkswagen Group on Social Rights, Industrial Relations and Business and Human Rights (the “Social Charter”).

Organization

WirelessCar Sweden AB, owned by CARIAD Group (a subsidiary of the Volkswagen Group), delivers connected vehicle services by integrating telematics, mobile network operators, and various service touchpoints. Our global footprint spans three continents, with Europe being our primary base for customers, personnel, and suppliers.

Although our operations and supply chain are considered low-risk in terms of exposure to modern slavery—given the nature of our digital and white-collar services—we nonetheless recognize our responsibility to maintain high standards of ethical conduct and due diligence throughout our business relationships.


Our Commitment

WirelessCar maintains a zero-tolerance policy towards slavery and human trafficking. We require all individuals and entities associated with our business—including employees, contractors, suppliers, and business partners—to uphold these values and ensure that modern slavery has no place in any part of our operations or supply chains.

We also expect that our suppliers extend the same expectations to their own supply networks.


Governance, Policies and Internal Measures

Code of Conduct

Our Code of Conduct, adapted from Volkswagen Group’s, is accessible to employees, suppliers, and customers via our website. It reinforces compliance with national and international laws and explicitly prohibits modern slavery and human trafficking. Respect for human rights is a core value embedded in the document, aligned with the UN Guiding Principles on Business and Human Rights and the UN Global Compact.

Whistleblower System

WirelessCar has an established Whistleblower System that enables employees, customers, and partners to report suspected violations, including human rights abuses. Reports can be made anonymously through country-specific channels or escalated internally to a designated body comprising our Head of Legal & Compliance, Legal Manager, and Head of People and Talent Growth. Retaliation against whistleblowers is strictly prohibited.

Risk Management

We incorporate human rights and compliance considerations into our broader risk management processes. Risks that cannot be resolved at the operational level are escalated promptly. We apply these principles across various business areas, including partner due diligence.

HR Compliance

Human Resources policies, including directives on diversity and harassment, promote fair treatment and a safe working environment. These documents safeguard employees and prospective hires from exploitation.


Training

All employees are required to complete mandatory Code of Conduct training every two years. This training addresses human rights, modern slavery, and business partner due diligence. An awareness test is part of the training, and failure to complete it results in sanctions.

From 2024 onwards, Business and Human Rights training is mandatory for all personnel. In addition, procurement staff receive targeted training on identifying and escalating potential risks in the supply chain.


Our Supply Chain and Due Diligence

Supplier Expectations

WirelessCar expects suppliers to operate in line with legal and ethical standards and use only legitimate resources. Most of our suppliers are multinational companies with their own corporate responsibility frameworks.

Supply Chain Risk Mitigation

We aim to identify and minimize supply chain risks using tools such as audits and certifications. Our approach is codified in the following:

  • Policy on Supplier Relations Sustainability – focusing on environmental, social, and anti-corruption standards across the value chain.
  • Business Partner Due Diligence Policy (BPDD) – a risk-based vetting process conducted before entering or continuing supplier relationships.

We have not identified any instances of modern slavery in our supply chain to date.


Business Partner Due Diligence

The BPDD process assesses whether existing and prospective business partners comply with laws and ethical standards. This review influences decisions to enter or terminate commercial relationships.


This statement is approved by the Management Team of WirelessCar Sweden AB

Signed:

Signed by Niklas Florén, CEO WirelessCar

Date: 29 August 2025