Legal

1. Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms,
such as slavery, servitude, forced and compulsory labour and human trafficking, all of which
have in common the deprivation of a person’s liberty by another in order to exploit them for
personal or commercial gain.

The Group has a zero-tolerance approach to modern slavery, and we are committed to acting
ethically and with integrity in all our business dealings and relationships and to implementing
and enforcing effective systems and controls to ensure modern slavery is not taking place
anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our
approach to tackling modern slavery throughout our supply chains, consistent with our
disclosure obligations under the local legislation. We expect the same high standards from
all our contractors, suppliers and other business partners, and as part of our contracting
processes, we include specific prohibitions against the use of forced, compulsory or
trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we
expect that our suppliers will hold their own suppliers to the same high standards.

This policy is not contractual and does not therefore contribute to the terms of employment.

2. Child Labour

The Group will not tolerate the use of child labour or the exploitation of children in any of its
global operations.

Child labour that is prohibited under international law falls into three categories:

• • • • • The unconditional worst forms of child labour, which are internationally defined as
          slavery, trafficking, debt bondage and other forms of forced labour, forced
          recruitment of children for use in armed conflict and other illicit activities.
        • Labour performed by a child who is under the minimum age specified for that
          kind of work (as defined by national legislation, in accordance with accepted
          international standards), and that is thus likely to impede the child’s education
          and full development.
        • Labour that jeopardizes the physical, mental or moral well-being of a child, either
          because of its nature or because of the conditions in which it is carried out,
          known as “hazardous work”.

In the conduct of its business, the Group will not employ children that fall into any of these
categories. The Group is against all forms of exploitation of children and does not provide
employment to children. The Group expects its clients and business partners to have and
uphold similar standards. Should any violation of these standards become known to the
Group, we will take serious action, including terminating the relevant business relationship. It
is the responsibility of the Group Operations Team to implement and ensure compliance with
this policy.

We have a legal obligation under the UK Modern Slavery Act 2015 to publish an annual
statement setting out the steps that we have taken to ensure that modern slavery is not
occurring in our organisation or supply chain. You have an important role to play in identifying
and addressing any risks presented by working with our suppliers, sub-contractors and other
business partners.

We need your support in monitoring and actively managing the risks associated with these
activities to ensure that the Group’s supply chain is and remains slavery-free.
This policy applies to all persons working for us or on our behalf in any capacity, including
employees at all levels, directors, officers, agency workers, seconded workers, volunteers,
interns, agents, contractors, external consultants, third-party representatives and business
partners.

As stated above, this policy does not form part of any employee’s contract of employment,
and we may amend it at any time. All amendments will be managed via version control and
the updated policy shown on our website.

3. Policy Approach

The Group has written policies on equal employment opportunities and whistleblowing that
are communicated to all employees when they first join the company. These policies
underpin fair and legal employment practices across the Group.

We may conduct pre-employment screening on hires for their right to work in their main
country of employment before they begin their role, and we support employees who wish to
relocate to do so in the right way.

The Group has an internal procurement policy which includes a commitment to purchasing
only from suppliers that will provide information on their fair working practices and opposition
to modern slavery and human trafficking.

4. Dealing with suppliers

It is important to communicate our zero-tolerance approach to slavery to all suppliers,
contractors and business partners at the outset of the business relationship and continuously
reinforce it.

To ensure that all suppliers adhere to the requirement before a new supplier can be approved,
we request that they sign up to the code of conduct. For all existing suppliers we will perform
due diligence either at the time of renewal of contract or new use of service / product.

If the Group discovers that anyone in our supply chain does not comply with our required
standards, we will take appropriate action. Depending on the nature and severity of the non
compliance and the country in which the relevant supplier is based, this may include
immediate termination of the contractual relationship. When deciding on the appropriate action
to take, we will take account of the wellbeing of the affected workers.

5. Communication, training and awareness of the policy

Training on this policy, and on the risk our business faces from modern slavery in its supply
chains, forms part of the induction process for all individuals who work for us, and regular
training will be provided as necessary.

Our commitment to addressing the issue of modern slavery in our business and supply
chains must be communicated to all suppliers, contractors and business partners at the
outset of our business relationship with them and reinforced as appropriate thereafter.

6. Breaches of Policy

The Group takes its commitment to keeping its business and supply chain free from slavery
very seriously. Any employee who breaches this policy will face disciplinary action, which
could result in dismissal for misconduct or gross misconduct. We may terminate our
relationship with other individuals and organisations working on our behalf if they breach this
policy.

7. Compliance with the policy

You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or
supply chains is the responsibility of all those working for us or under our control. You are
required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify the compliance manager as soon as possible if you believe or suspect that a
conflict with this policy has occurred or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any
parts of our business or supply chains of any supplier tier at the earliest possible stage.
You should note that where appropriate, and with the welfare and safety of local workers as
a priority, we may give support and guidance to our suppliers to help them address coercive
or exploitative work practices in their own business and supply chains.

If you are unsure about whether a particular act, the treatment of workers more generally, or
their working conditions within any tier of our supply chains constitutes any of the various
forms of modern slavery, raise it with the compliance manager.

We aim to encourage openness and will support anyone who raises genuine concerns in
good faith under this policy, even if they turn out to be mistaken. We are committed to
ensuring no one suffers any detrimental treatment as a result of reporting in good faith their
suspicion that modern slavery of whatever form is or may be taking place in any part of our
own business or in any of our supply chains. Detrimental treatment includes dismissal,
disciplinary action, threats or other unfavourable treatment connected with raising a concern.
If you believe that you have suffered any such treatment, you should inform the compliance
manager immediately. If the matter is not remedied, and you are an employee, you should
raise it formally using our Grievance Procedure.

8. Responsibility for this policy

The Group Board of Directors has overall responsibility for ensuring this policy complies with
our legal and ethical obligations, and that all those under our control comply with it. The
Board of Directors gives the responsibilities of “compliance manager” to the Group
Operations Team.

The compliance manager has primary and day-to-day responsibility for implementing this
policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing
internal control systems and procedures to ensure they are effective in countering modern
slavery.

Management at all levels are responsible for ensuring those reporting to them understand
and comply with this policy and are given adequate and regular training on it and the issue of
modern slavery in supply chains.

You are invited to comment on this policy and suggest ways in which it might be improved.
Comments, suggestions and queries are encouraged and should be addressed to the
compliance manager.

9. Version Control

Date of issue: September 2025
Issuing Department: Catalis Group
Date of next review: September 2026
This is a living document; The Group encourages all employees, suppliers, contractors and
business partners to provide feedback, comments and suggestions and raise queries on this
policy in order to ensure its continued efficacy. Please address these to the Compliance
Manager.