Introduction from Astroscale Limited Managing Director, Nick Shave
Astroscale Limited (“Astroscale”) ensures that we trade ethically, source responsibly, and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain. Astroscale takes and always has taken a zero-tolerance approach to modern slavery and human trafficking. This statement highlights the key activities we have undertaken during this financial year to combat modern slavery and human trafficking in our organisation, supply chain and among Astroscale’s clients.
Organisational structure and business
Astroscale is the global leader of on-orbit servicing, dedicated to the safe and sustainable development of space supporting a growing customer base. Astroscale focused on delivering a variety of innovative and scalable on-orbit servicing solutions, including life extension, in-situ space situational awareness, end-of-life, and active debris removal. We operate mainly in the United Kingdom as one of Astroscale Holdings Inc. locations. Astroscale Holdings Inc. have offices in the United States, Israel and France as well as headquarters in Tokyo, Japan.
Our Supply Chain
Astroscale’s supply chain primarily comprises suppliers of high-technology products, professional services, manufacturing and office-related goods and services. Professional service providers include data licensors, consultants, agents across sectors such as defence and space systems, and external legal counsel. Office services encompass delivery, catering, maintenance, repair, and cleaning. Office goods include IT hardware and software, photocopiers, telecommunications equipment, furniture, and general office supplies. Astroscale’s supply chain also includes electronic goods, including electronic components, providers of raw materials and raw material conversion, and rare earth materials.
Our Policies on Slavery and Human Trafficking
Astroscale has a zero-tolerance policy for slavery and human trafficking. We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all of our policies.
This policy is included as part of our Employee Handbook and reflects our commitment to acting ethically and within integrity in all Astroscale business relations, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere within our supply chains and our values are compiled with.
Astroscale’s Employee Handbook expressly prohibits employees from: (a) engaging in any forms of trafficking of persons; (b) procuring sex acts of any kind; (c) using forced labour; or (d) engaging in any other activities deemed unlawful by the Victims of Trafficking and Violence Prevention Act (TVPA). Employees who are believed to have participated in human trafficking activity of any kind are referred to the appropriate authorities for possible criminal prosecution. Astroscale employees are advised to report trafficking concerns to Astroscale’s Deputy Managing Director Sharon Parker Lines, to the Global Human Trafficking Hotline at 1-844-888-FREE, or by emailing concerns to help@befree.org.
Astroscale has the following policies in place relevant to modern slavery, which we continuously review and update:
Whistleblowing Policy
A thorough recruitment process featuring numerous checks on eligibility of each and every Astroscale employee for UK employment.
A code of conduct detailed in our Employee Handbook; and
A vetting process for all business partners and signing of compliance with modern slavery and human trafficking policy where business partners do not have a policy of their own.
Due diligence processes for slavery and human trafficking
Astroscale believe the risks of slavery and human trafficking practices directly within our business are low. Our office services suppliers are engaged in a range of activities, from higher skilled to lower skilled, but almost all are engaged in services conducted in close proximity to or in close cooperation with Astroscale personnel. Consequently, these services are conducted in a professional environment where exploitive practices would be difficult, if not impossible, to hide. Our suppliers of office goods are reputable retailers and wholesalers. We do not contract with source suppliers based in industries or regions of the world where the risks of modern slavery and human trafficking are relatively high.
As part of our initiative to identify and mitigate risk we have in place processes to:
Identify and assess potential risk areas in our supply chains by conducting a due diligence review on all of our supply chain partners over agreed thresholds stated within Astroscale’s Procurement Policy via SAM and Office of Foreign Assets Control (OFAC) reviews; by conducting these reviews and verifying or eliminating current or potential supply chain partners on a pass/fail basis allows us to:
Mitigate the risk of slavery and human trafficking occurring in our supply chains; and
Monitor potential risk areas in our supply chains;
Protect whistleblowers. We encourage anyone who suspects modern slavery or human trafficking to report it immediately either to Deputy Managing Director, Sharon Parker Linkes or to an established whistleblowing hotline.
Adherence to our values
To ensure clients, stakeholders, partner organisations in addition to all those in the supply chain and contractors comply with our values, we are adding supply-chain specific elements to our compliance program. At a minimum, Astroscale will include contract clauses in all contracts with any and all members of the supply chain, clients, contractors and stakeholders, requiring compliance with appropriate human trafficking and modern slavery policies. As Astroscale currently holds Direct Commercial Sale in the United Kingdom an example is our inclusion of Government customer standard contract clauses in subcontract agreements with the supply chain thus these clauses including Modern Slavery Act of 2015 adherence, respectively.
Deputy Managing Director Sharon Parker Lines work with our Legal, Procurement, and HR teams on issues relating to slavery and human trafficking. All Astroscale consultants are included in our annual ethics training, which includes matters relative to modern slavery and human trafficking.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide annual ethics training to our staff. Further, we require our supply chain to provide Astroscale with an annual certification confirming compliance with anti-modern slavery and human trafficking regulations and laws within their companies.
Our effectiveness in combating slavery and human trafficking
Each year, 100% of Astroscale’s staff, contractors and all consultants receive annual ethics training, to include awareness of Astroscale’s zero tolerance policy of slavery and human trafficking as well as avenues for reporting any concerns. To date, Astroscale has received no reported breaches.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2024. It was approved by the UK Leadership Team on 24th June 2025.
