Modern Slavery Statement
Zero tolerance for forced labour in any form.
This statement is published by Wavestar Holdings LLC under Section 54 of the UK Modern Slavery Act 2015 and in keeping with the principles of the California Transparency in Supply Chains Act 2010 and the Australian Modern Slavery Act 2018. It describes the steps Wavestar takes to ensure that slavery, servitude, forced labour, human trafficking, and child labour are not taking place in any part of its business or any part of its supply chain.
- Statute
- UK Modern Slavery Act 2015 · § 54
- Reporting period
- Calendar year 2026
- Approved by
- Board of Directors
- Approval date
- Annual · next Q1 2027
Organisation and structure
Who we are and how we operate.
Wavestar Holdings LLC is a Wyoming limited liability company building the clearing, settlement, and truth layer for the orbital economy. At the time of publication the organisation employs a small core team across the United States and contracts with specialised suppliers for engineering, regulatory, audit, cloud infrastructure, and physical operations.
Company profile
- Legal entity
- Wavestar Holdings LLC
- Jurisdiction of formation
- Wyoming, United States
- Principal place of business
- New York, New York
- Industry
- Financial-market infrastructure (FMI) for orbital resources
- Workforce
- Permanent employees, salaried contractors, professional advisers
- Supplier relationships
- Cloud infrastructure, cryptographic hardware, regulatory counsel, external audit, pen-testers, facilities
Risk assessment
Where modern-slavery risk is concentrated.
A proportionate annual risk assessment identifies where modern-slavery risk is most likely to arise in Wavestar's operations and supply chain. The assessment draws on the Global Slavery Index, the US Department of Labor list of goods produced by child or forced labor, and guidance from the Home Office Statutory Guidance (2020).
- 01
Direct workforce
Low inherent risk. Wavestar engages skilled professional workers in high-wage jurisdictions, with right-to-work verification, direct written contracts, and direct payment of wages into worker-named accounts. - 02
Cloud and infrastructure suppliers
Low inherent risk. Primary suppliers are large publicly held enterprises with their own published modern-slavery statements and audited human-rights programs. - 03
Cryptographic hardware suppliers
Moderate inherent risk. Hardware supply chains touch raw-mineral and electronics-assembly sectors with known labour-risk hotspots. Addressed via supplier certification and Responsible Business Alliance alignment. - 04
Facilities and professional services
Low-to-moderate inherent risk. Cleaning, security, and physical-facilities contractors are a recognised risk category addressed via contractual commitments and worker-interview sampling. - 05
Prospective ground-station operator suppliers
Moderate inherent risk depending on jurisdiction. Addressed via operator due-diligence at onboarding, including a supplier labour-practices declaration. - 06
Third-party financial services
Low inherent risk. Banks, custodians, and counterparty clearers are regulated entities with their own modern-slavery compliance obligations.
Due diligence
What we do to address the risk.
- 01
Supplier code of conduct
Every new supplier acknowledges the Wavestar Supplier Code of Conduct at onboarding, which explicitly prohibits forced labour, child labour, and human trafficking, and requires supplier cooperation with audits. - 02
Contractual obligations
Standard contract terms include a modern-slavery representation, a right to audit, and a right to terminate on a material modern-slavery breach. Flow-down requirements apply to sub-contractors. - 03
Risk-rated diligence
Suppliers are risk-rated at onboarding. Moderate and high-risk suppliers complete a detailed questionnaire covering workforce composition, recruitment practices, grievance mechanisms, and sub-tier transparency. - 04
Workforce policies
Right-to-work verification on hire, zero recruitment-fee charged to workers, direct deposit of wages, and freedom of association. All workforce policies are published in the employee handbook. - 05
Grievance mechanism
The Wavestar Speak-Up hotline, operated by an independent vendor, is available 24/7 to any worker in the operations or supply chain, anonymously, in multiple languages. Reports of modern-slavery concerns are escalated immediately to the CCO. - 06
Training
Modern-slavery awareness training is delivered annually to procurement, supplier-management, and onboarding staff, and included in the general ethics training for all employees.
Effectiveness
How we measure whether the program works.
Program indicators · baseline 2026
- Suppliers onboarded with code acknowledgement
- 100%
- High-risk suppliers with completed diligence questionnaire
- 100%
- Modern-slavery training completion · in-scope staff
- 100%
- Modern-slavery concerns reported via hotline
- 0 in reporting period
- Confirmed findings
- 0
- Remediation actions taken
- Not applicable in reporting period
Commitments
What we will do next.
Approval
Signed at the top.
This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and constitutes the Wavestar Holdings LLC modern-slavery and human-trafficking statement for the reporting period stated above. The statement has been approved by the Board of Directors and signed on the Board's behalf by the Chief Executive Officer.
Modern-slavery concern
Report a concern.
Anyone with a modern-slavery concern about Wavestar's operations or supply chain can report it confidentially through the Speak-Up hotline. Reports can be made anonymously. Retaliation is prohibited.