Modern Slavery Statement


   Heylean continually works to prevent slavery and human trafficking from taking place in our manufacturing supply chains and operations, in line with the United Kingdom Modern Slavery Act.


OUR BUSINESS

   Heylean.com founded in January 2020. Heylean.com is providing next generation cloud native security platform products and services for Businesses and Governments. We want to create more secure World with latest technologies.

   Heylean is a profit company. But, we give more importance to the loyalty of those who use our services. We re-design technology and build future of our civilization. Our Earth needs technology and we want to re-design our Earth by using the right technology at the right time.

   We have principles and we are working always for this principles. Our principles; Focus on the people, focus on the future, innovation for greater good, empathize, ethics and innovation.

   Our Supply Chain: Heylean.com is committed to improving the working conditions of people around the world who are a part of our supply chain. With manufacturers spanning the Americas, Asia, Australia, Europe, and Africa, we recognize the need to monitor for conditions that put    workers at risk of forced labour.

   We utilize independent contractors and temporary personnel to supplement our workforce. We have works councils and statutory employee representation obligations so that we can engage directly with our workers to maintain and encourage open dialogue.

   These code of conducts;

   Our suppliers must not use forced labour - slave, prison, indentured, bonded, or otherwise.

   Our suppliers must not traffic workers or in any other way exploit workers by means of threat, force, coercion, abduction, or fraud. Working must be voluntary, and workers must be free to leave work and terminate their employment or other work status with reasonable notice.

   Workers shall not be required to pay recruitment, hiring, or other similar fees related to their employment; our suppliers must bear or reimburse to their workers the cost of any such fees. All fees and expenses charged to workers must be disclosed to Heylean and communicated to    workers in their native language in advance of employment.

   Our suppliers must not require workers to surrender government issued identification, passports, or work permits as a condition of working, and our suppliers may only temporarily hold onto such documents to the extent reasonably necessary to complete legitimate administrative and    immigration processing.

   Workers must be given clear, understandable contracts regarding the terms and conditions of their engagement in a language understood by the worker.

   Suppliers must ensure that each of its staffing or recruiting agencies comply with this Supplier Code and with the more stringent of the applicable laws of the country where work is performed and the worker’s home country.


RISK ASSESSMENT

   We use a combination of desk-based research, supply chain mapping against existing human rights indices, as well as internal and industry audit results to analyse the risk of modern slavery in our supply chain and operations. While modern slavery can be found in all countries and    industries , we acknowledge that there is a heightened risk with

   domestic and international migrant labour;

   contract, agency, and temporary workers;

   vulnerable populations (e.g. refugees); and

   young, or student workers.

   In addition to the controls listed below, this year Heylean launched a process to investigate suppliers with a heightened risk of modern slavery specifically in relation to migrant workers. Our process focuses on listening to workers' perspectives about their recruitment experience and    working/living conditions, and relating anonymous feedback from workers directly to management to drive improvement. In addition, we are expanding regional teams to engage with suppliers in high-risk regions, and working with industry programmes.


DUE DILIGENCE PROCESSES

   Heylean assesses manufacturing suppliers and service providers for continued compliance and improvement. Heylean uses a risk-based approach to determine the frequency of assessments and which manufacturing suppliers and service providers should be assessed. Many sites are    assessed multiple times a year, including through follow-up assessments to address specific findings. Heylean may terminate its relationships with any supplier that violates our Supplier Code or does not cooperate during assessments. Assessments may include:

   Site inspection of all areas of the site and any living quarters;

   Confidential worker interviews or surveys conducted without site management present;

   Review and analysis of site documents or licenses to assess workers' age, contracts, compensation, working hours, and workplace conditions;

   Identification of past compliance issues, areas for improvement, and development of a remediation plan.

   Audit reports and findings are reviewed regularly by senior leadership and corrective action plans are implemented as needed. Heylean tracks remediation closely and conducts follow-up audits for significant issues. Between audits, Heylean employees meet on-site with supplier    managers to discuss open issues and remediation progress.

   Suppliers are required to remediate violations of Heylean's Supplier Code of Conduct. Suppliers must submit a Corrective Action Plan (CAP) providing both a root cause analysis and a description of remedy. Heylean evaluates CAPs in light of the severity level of the violation.


PARTNERSHIPS AND STAKEHOLDER ENGAGEMENT

   To ensure that our policies and programs incorporate internationally recognized human rights standards, we conduct formal benchmarking with industry and multilateral groups to design, operate, and continually improve our risk assessment and audit program.


ASSESSMENT OF EFFECTIVENESS

   Suppliers manufacturing Heylean private label products are assessed for compliance with Heylean's Supplier Code of Conduct before Heylean begins ordering products, and we expect all of our suppliers and service providers to meet the standards in our Supplier Code of Conduct as a    condition of doing business with us. These facilities must demonstrate the absence of any issue that has caused or is likely to cause immediate harm to workers or communities, or demonstrates egregious unethical behavior, including the use of forced or indentured labour, or human    trafficking. In the event an issue that has caused or is likely to cause severe harm to workers is identified prior to beginning a relationship with Heylean, the issue must be resolved before, and as a condition of, initial production and to qualify for continued production with Heylean.    Heylean's    sourcing teams have each taken on Social Responsibility goals to monitor for these conditions at an executive leadership level; performance against these goals is regularly reported to leadership.

   The Social Responsibility team consults with Heylean business teams on new sourcing geographies and sourcing teams are responsible for reviewing supplier performance before moving to production.


SUPPORT AND CAPACITY BUILDINGS

   We offer suppliers training to help understand Heylean requirements before audits, effectively navigate the Corrective Action Plan (CAP) process, and design and implement sustainable management systems after an audit. We have dedicated teams that work directly with suppliers and    service providers in major geographies. We offer on-site and remote training to support continuous improvement. Suppliers are also encouraged to participate in external training programs, such as industry association tutorials related to recognizing and preventing forced labour and    implementing management systems. We are continuously exploring ways to use Heylean's expertise to expand this support.

   Employees of Heylean take mandatory compliance training courses on the Code of Business Conduct and Ethics, Anti-Bribery Compliance, and Workplace Harassment. Additionally, the Heylean.com Legal Department has developed and maintains reporting guidelines for employees    who wish to report violations of the Business Code of Conduct and Ethics. These guidelines include information on making reports to the Legal Department and to an independent third party.


APPROVAL FOR THIS STATEMENT

   This statement was approved by the Heylean European Board of Directors and covers all activities undertaken by Heylean's UK entities.

   HEYLEAN.COM, LTD. - United Kingdom Operations

   Furkan CONTAR