Modern Slavery Statement

1. Introduction

Tungstenum, owned and controlled by Ziken Labs Società a Responsabilità Limitata Semplificata, is committed to the highest standards of integrity, governance and responsible business conduct. We recognise that modern slavery, human trafficking, forced labour and child labour remain serious global issues, and we are determined to ensure that our business and supply chain are entirely free from such practices.

As an investing strategies provider operating in the financial and digital assets sector, Tungstenum works with international stakeholders, data vendors, technology providers and professional service firms. Our position within the financial ecosystem carries with it a responsibility: not only to deliver robust and innovative investment strategies, but also to ensure that our operations contribute positively to society and respect fundamental human rights.

2. Our business context

Tungstenum is developing index strategies designed for B2B2C platforms, institutional and professional investors. While we do not manufacture physical products, our value chain involves a network of suppliers and partners providing services such as technology infrastructure, financial data, marketing and consultancy. This globalised and interconnected supply chain presents potential exposure to human rights risks, which we are committed to identifying, assessing and mitigating.

3. Governance and accountability

Responsibility for overseeing human rights and modern slavery compliance lies with the executive leadership of Ziken Labs, the parent company of Tungstenum. Governance is embedded within our broader ESG (Environmental, Social and Governance) framework, ensuring that the fight against modern slavery is not a standalone initiative, but part of a comprehensive approach to responsible business.

Our governance structure includes:

  • Board oversight: Regular reviews of policies and risk assessments.
  • Management responsibility: Operational teams are required to implement due diligence procedures with suppliers and partners.
  • Employee awareness: Training and guidance to recognise potential risks and escalate concerns.

4. Policies and standards

We operate under a strict Code of Conduct which applies to all employees, contractors and suppliers. This includes explicit prohibitions against forced or exploitative labour, and requires compliance with international standards such as:

  • The UN Guiding Principles on Business and Human Rights.
  • The International Labour Organization (ILO) Conventions.
  • The OECD Guidelines for Multinational Enterprises.

Suppliers and service providers are expected to confirm adherence to these standards. Where necessary, we reserve the right to audit or request further documentation.

5. Supply chain risk management

Given our reliance on professional services and technology partners, our primary focus is on evaluating and managing risks within these domains. Actions taken include:

  • Risk mapping: Assessing suppliers according to geography, industry and service type.
  • Due diligence: Integrating human rights considerations into supplier selection and contracting.
  • Ongoing monitoring: Reviewing supplier practices and requesting compliance confirmations.

6. Actions taken during the year

  • Conducted an internal review of our direct suppliers and partners.
  • Introduced clauses on human rights and modern slavery into new contracts.
  • Strengthened employee awareness sessions within Ziken Labs regarding modern slavery risks in the technology and services sectors.

7. Future commitments

Tungstenum and Ziken Labs remain committed to continuous improvement. Our future priorities include:

  • Expanding supplier assessments with a focus on ESG and human rights performance.
  • Enhancing transparency by publishing annual updates on progress and findings.
  • Deepening employee training to cover emerging risks in fintech and digital asset markets.
  • Collaborating with industry peers to promote higher standards across the financial services ecosystem.

8. Conclusion

At Tungstenum, we believe that ethical and sustainable practices are not only a legal obligation but a fundamental component of long-term value creation. By embedding the fight against modern slavery into our governance, supply chain and stakeholder engagement, we reinforce our commitment to being a responsible and trusted partner in the financial sector.

9. Approval

This statement has been approved by the management of Ziken Labs, parent company of Tungstenum, and will be reviewed annually to ensure ongoing relevance and effectiveness.

Signed,
Fabrizio Pepe, CEO
For and on behalf of Ziken Labs (owner and controller of Tungstenum)