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Modern Slavery Statement

Financial year ending 31st December 2025

Published: 30th March 2026

This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and sets out the steps that Obscurity Ltd has taken, and continues to take, to ensure that modern slavery and human trafficking are not taking place within our business or supply chain.

1. About Obscurity Ltd

Obscurity Ltd is an analytics governance consultancy registered in Ireland (CRO 737010). We provide analytics governance consulting services and software tools to regulated organisations, primarily in the insurance and energy sectors in Ireland and the United Kingdom. Our principal activities are analytics governance consulting and advisory services, tag management, compliance auditing and monitoring, and the development and operation of governance software tools. We employ a small team based in Ireland and engage a limited number of contractors and technology service providers.

2. Our Supply Chain

Our supply chain consists primarily of cloud infrastructure and software providers (major technology companies), professional services providers (accountancy, legal, and insurance based in Ireland), and specialist technology contractors engaged on documented terms. We do not have complex manufacturing supply chains, do not source raw materials, and do not engage recruitment agencies or labour providers.

3. Our Policies

We have the following policies in place that are relevant to modern slavery prevention:

4. Due Diligence

We carry out the following due diligence in relation to modern slavery: supplier assessment as part of supplier onboarding considering the nature of the supplier's business, geographic risk factors, and workforce composition; contractual requirements that mandate compliance with all applicable labour laws and prohibit forced, bonded, or compulsory labour; and ongoing monitoring through periodic review of supplier relationships. Given the nature of our supply chain (predominantly technology and professional services in Ireland and the UK), our assessed risk of modern slavery is low. However, we remain vigilant and committed to taking action if any concerns arise.

5. Risk Assessment

We have assessed the risk of modern slavery occurring in our business and supply chain. Our team members are highly skilled professionals engaged on documented contracts with fair terms. We do not employ low-skilled, temporary, or migrant workers. Our suppliers are predominantly established technology and professional services companies operating in low-risk jurisdictions. Our operations and supply chain are concentrated in Ireland and the United Kingdom, which are low-risk jurisdictions for modern slavery, though we recognise that no jurisdiction is entirely free from risk.

6. Steps Taken in the Financial Year

During the financial year ending 31st December 2025, we published our Labour Standards Policy setting out our commitments and requirements, reviewed supplier contracts to ensure they include appropriate anti-slavery provisions, ensured all contractors are engaged on documented terms with fair payment conditions, and maintained our Protected Disclosures Policy as a reporting mechanism for concerns.

7. Training

All employees and contractors receive awareness of modern slavery risks and our reporting mechanisms as part of their onboarding. The Managing Director maintains oversight of compliance with our labour standards commitments.

8. Effectiveness

We measure the effectiveness of our approach through the number of modern slavery concerns reported (FY2025: nil), completion of supplier due diligence for new suppliers, and review and update of relevant policies. No instances of modern slavery or human trafficking were identified in our business or supply chain during the reporting period.

9. Approval

This statement has been approved by the board of directors of Obscurity Ltd and is signed by the Managing Director.

Dónal Troddyn
Managing Director, Obscurity Ltd

Date of publication: 30th March 2026