Introduction

Section 54(1) of the United Kingdom Modern Slavery Act 2015 (the “Act”) requires certain businesses to annually disclose information concerning the efforts taken to prevent slavery and human trafficking within their own businesses and in their respective supply chains.

Notion Labs, Inc. is a Delaware corporation headquartered in San Francisco, California, with a presence in the United Kingdom and other markets around the world. References to “we” or “our” in this statement (this “Statement”) refer to Notion Labs, Inc. (“Notion”).

This Statement constitutes Notion’s modern slavery and human trafficking disclosure pursuant to Section 54(1) of the Act for our fiscal year ended January 31, 2026.

Our Commitment to Combat Modern Slavery and Human Trafficking

Notion is committed to conducting our business ethically and responsibly. We recognize the importance of the Act and our duty to uphold its principles by working to identify and mitigate risks of modern slavery and human trafficking and working to ensure our operations and supply chain are free from these practices.

Our Business Operations and Supply Chain

Notion is the connected AI workspace that brings all work together in a tool that adapts to every team—with AI to find answers and automate busywork. It's one place to search, manage projects, capture notes and company knowledge, and collaborate as a team.

While our procurement team is based in the United States, Notion engages with suppliers across the globe, with the majority located in the countries in which Notion operates, including, but not limited to, the United States, Australia, India, Japan, South Korea, the United Kingdom, and various countries within the European Union. Some suppliers service our entire company, while other vendors are local or regional and fulfill specific needs for our various offices around the world. Notion is not a manufacturer and we do not purchase raw materials or commodities for use in our business operations. Rather, our supply chain primarily consists of goods and services including, but not limited to, computing and software services, customer support, event planning, catering services, IT equipment, purchase of retail items, office supplies, office cleaning services, food and beverage, leasing of facilities, such as office space, and professional services, such as legal and accounting firms.

Risk Assessment

Based on numerous factors, including our business model, the nature of our products and services, the locations in which we and our suppliers operate, and our global procurement practices, we believe the overall risk of modern slavery and human trafficking in our business and supply chains to be low. Nevertheless, we recognize that our procurement of goods and services is merely part of the broader global supply chain and there is some inherent risk in every operation.

To date, we have not discovered any modern slavery or human trafficking in our business or supply chain and have no credible basis to believe that such practices have occurred or are occurring. If we become aware of allegations or evidence of such practices, Notion would immediately conduct an investigation and take appropriate remedial action including, but not limited to, terminating the supplier relationship and, if necessary, informing the relevant authorities and/or law enforcement agencies.

Risk Management

We remain committed to ethically and responsibly conducting our operations and have taken steps to assess and manage the risk of modern slavery and human trafficking in our operations and supply chain, including the adoption of policies that set forth our values and govern the way we do business.

Code of Ethics and Business Conduct

Notion’s commitment to ethical business conduct is memorialized in our Code of Ethics and Business Conduct (the “Code”), which applies to all of our employees, contingent workers, officers, and board members (collectively, “Notion personnel”). The Code sets forth our policies with respect to topics such as conflicts of interest, anti-bribery, global trade compliance, and anti-harassment and discrimination, and affirms our obligation to report all illegal activities under applicable law.

All Notion personnel are required to read and complete an acknowledgment of the Code and are encouraged to be proactive with respect to the principles set forth therein. This includes an expectation that all Notion personnel will report suspected violations of the Code; Notion values, policies, or procedures; or applicable law. Notion offers several reporting channels for Notion personnel who may have ethical or legal concerns, and promotes those channels through internal policies, communications, and trainings. Any allegations of modern slavery or human trafficking will be investigated internally under the oversight of Notion’s General Counsel. Notion strictly prohibits retaliation against any individual who reports a modern slavery or human trafficking concern or any other suspected violation of the Code; Notion values, policies, or procedures, or applicable law; or who refuses to participate in an activity that would result in a violation or noncompliance with applicable law.

Whistleblowing Hotline

Notion personnel are encouraged to report concerns relating to modern slavery, human trafficking, and other illegal or unethical activity through appropriate channels, including, without limitation, to supervisors, our HR team, directly to our General Counsel, or to the appropriate regulatory or legal authority. To enable reporting by Notion personnel, we maintain a third-party operated whistleblowing hotline, which includes a 24-hour telephone hotline and web portal that enables individuals to anonymously report suspected violations.

Compensation Practices