Human Rights

Our Commitment

Adept Technologies Limited ("Adept") is a women-founded technology and business process outsourcing company headquartered in Nairobi, Kenya, serving clients across East Africa and Europe. We are committed to respecting human rights in everything we do: in how we treat our people, how we deliver services to our clients, and how we work with suppliers and communities.

We recognise our responsibility to avoid causing or contributing to adverse human rights impacts, to address such impacts where they occur, and to support access to remedy. This policy reflects the Constitution of Kenya, 2010 and Kenyan labour and employment law, and is guided by internationally recognised human rights standards, including the Ten Principles of the UN Global Compact.

Scope

This policy applies to all Adept employees, whatever their contract type, and to all our operations. We expect our suppliers, contractors and other business partners to uphold equivalent standards, and we encourage our clients to integrate human rights principles into their own operations. In applying this policy, we also consider the communities where we operate.

Respect for Human Rights

We respect the inherent dignity, equality and fundamental rights of every person. We identify and manage human rights risks through due diligence that is proportionate to our size and operations, focusing on the most significant risks, such as working conditions and wellbeing in contact centre operations, privacy and data protection, and the labour practices of suppliers. Where we identify an adverse impact, we act to address it.

Fair and Inclusive Employment

We are committed to:

• Equal opportunity: recruitment, pay, training, promotion, performance management, discipline and termination decisions are based on merit and job-related criteria, without discrimination on grounds such as race, colour, sex, gender, pregnancy, marital status, health status, ethnic or social origin, nationality, age, disability, religion, belief, language, political opinion, sexual orientation or any other status protected by law.
• Fair pay: wages that meet or exceed the legal minimum, equal pay for work of equal value, and transparent pay practices. We aim to provide wages that reflect a living wage based on the local cost of living.
• Decent working conditions: written terms of employment, working hours and rest periods managed in accordance with the law, and statutory leave entitlements.
• Fair process: disciplinary and termination decisions that are lawful, fair and consistently applied.
• Inclusion of persons with disabilities: reasonable accommodation, progressive improvement of accessibility, and compliance with the Persons with Disabilities Act, 2025.
• Diversity, equity and inclusion at all levels of our organisation.

Safe and Respectful Workplace

We provide a safe and healthy working environment in line with the Occupational Safety and Health Act, 2007 and the Work Injury Benefits Act, 2007, including emergency preparedness, appropriate training and equipment, and wellbeing support that recognises the demands of BPO work.

We do not tolerate sexual harassment, bullying, intimidation, or abusive or degrading treatment, whether by colleagues, managers, clients or customers. These standards apply in our offices, in remote and online work, and at work-related events.

Prohibition of Forced and Child Labour

We prohibit all forms of forced, bonded and compulsory labour and human trafficking. We do not retain employees' original identity documents, charge recruitment fees or restrict employees' freedom of movement, and all employees are free to leave their employment in accordance with their contract and the law.

We do not use child labour. As a company standard, Adept does not employ any person under the age of eighteen (18) years, and we verify the age of candidates at recruitment. If forced or child labour is identified in our operations or supply chain, we will act in the best interests of the affected person and take appropriate remedial action.

Freedom of Association and Employee Voice

We respect our employees' right to join, or not to join, a trade union of their choice and to bargain collectively in accordance with the law, without fear of retaliation or discrimination. We encourage open, two-way communication between management and employees, and we seek employee feedback, including through surveys, to improve working conditions.

Privacy and Responsible Data Handling

We respect the right to privacy. Personal data of our employees, job applicants, clients and the individuals we serve on their behalf is processed lawfully, fairly and securely, in accordance with the Data Protection Act, 2019 and our Data Protection Policy. Where workplace monitoring is necessary, such as call recording for quality or client purposes, it is proportionate and communicated to employees in advance.

Business Partners and Suppliers

We expect our suppliers, contractors and business partners to:

• comply with applicable labour, employment and human rights laws;
• prohibit forced, bonded and child labour and human trafficking;
• provide safe working conditions and fair wages;
• respect freedom of association and prevent discrimination and harassment;
• protect personal data; and
• give their workers access to effective grievance mechanisms.

We communicate these expectations, include them in contracts where appropriate, and carry out risk-based checks. Where a business partner does not meet them, we work with the partner on corrective action and may review or end the relationship if concerns are not addressed.

Reporting Concerns and Non-Retaliation

Employees can raise concerns through Adept's internal grievance, harassment reporting and whistleblowing channels, including anonymously where the channel allows. Suppliers' workers, community members and other external stakeholders can raise human rights concerns by contacting hr@adept-techno.com.

All concerns are treated confidentially and investigated promptly and impartially, and we provide or cooperate in remedy where appropriate. We do not tolerate retaliation against anyone who raises a concern in good faith. This policy does not limit anyone's right to raise a concern with the relevant public authorities.

Governance, Monitoring and Review

Our Chief Executive Officer holds overall accountability for this policy, and our HR Department is responsible for its day-to-day implementation, supported by management across the business. We monitor implementation through internal reviews, employee feedback and key indicators, provide training to employees and managers, and report annually on our progress, including through our UN Global Compact Communication on Progress.

We review this policy at least every two years, or earlier where required by changes in law, our operations or stakeholder feedback, as part of our commitment to continuous improvement.

Relevant Standards and Commitments

This policy is aligned with:

• Kenyan law: the Constitution of Kenya, 2010; the Employment Act, 2007; the Labour Relations Act, 2007; the Occupational Safety and Health Act, 2007; the Work Injury Benefits Act, 2007; the Persons with Disabilities Act, 2025; the Children Act, 2022; the Counter-Trafficking in Persons Act, 2010; and the Data Protection Act, 2019.
• International standards: the Universal Declaration of Human Rights; the UN Guiding Principles on Business and Human Rights; the ILO Declaration on Fundamental Principles and Rights at Work; Principles 1 to 6 of the UN Global Compact; and the Sustainable Development Goals, in particular SDG 5, SDG 8 and SDG 10.

Approved by the Chief Executive Officer, Adept Technologies Limited. Version V (01), September 2026.