We don’t employ children, nor do we confiscate employee identification documents. We don’t permit compulsory overtime, nor do we allow worker-paid recruitment fees, as we deem this to be bribery and corruption.

We uphold people rights to have the freedom to terminate their employment with us, enjoy freedom of movement, and freedom of association. We therefore do not prevent any employee from joining any trade union. Working practices are also designed with the welfare of our employees in mind, by ensuring their physical, mental, and emotional wellbeing is maintained and free from any threats of violence, harassment, and intimidation. We prohibit all forms of discrimination and promote equity, diversity, and inclusion within the workplace because everyone matters.

Risk assessment

Zellis Group operates group wide enterprise risk management practices with localised and group-level reporting routes governed by an enterprise risk management system consisting of a framework, policy, and standard operating procedures. We apply a ‘principles and outcomes’ approach to the way we manage all types of risk. Both the corporate governance and enterprise risk management frameworks are matters reserved for the Zellis Holdings Board and are reviewed annually for adequacy. All our management systems integrate with each other within our group GRC Manual, forming a dynamic suite of collateral which humanises rules so that people naturally adopt the right behaviours and remain vigilant in detecting signs of modern slavery and human trafficking.

Within our economic crimes management system, our economic crimes framework is the primary document where modern slavery and human trafficking preventive measures are governed and managed. Due to its regulatory nature, we adopt a risk-based approach in the way we operationalise requirements. Modern slavery and human trafficking can be very hard to detect, especially when efforts are being made to hide this type of criminal and unethical activity. We proactively acknowledge emerging threats and adapt our controls environment to keep pace with new threats and trends through formalised, documented enterprise risk management processes.

We are fully aware of how to recognise signs of modern slavery and human trafficking through our internal controls, which would trigger further investigation if activity is suspected or identified. Our systems and controls ecosystem is under continual development, with collaboration between the skilled teams delivering our services and those maintaining compliance oversight and independent assurance over our supply chain.

Due diligence

We have reviewed the adequacy of our governance structure in accordance with our document management processes and are satisfied our commitment, policy, and operational provisions meet requirements.

We have continued to develop our education and awareness programme, aligning the messaging to the specific nature of our business, as well as highlighting the extent of the global exposure and the volume of victims in modern slavery. Whilst the risk exposures are low due to the nature of our business and core services, we are committed to making sure our employees stay alert and know what to do, should they identify any suspicious activity.

Our control objectives are mapped against enterprise risks and designed to classify the control type, outline the purpose of the control and why it exists. We also define how to perform the control to ensure signs of modern slavery and human trafficking are detected, prevented, and reported. We continue raising awareness within the wider community through internal campaigns to maintain a reasonable level of vigilance.

Our performance

Last year, we enhanced our visibility of the profiling of our supply chain through our supplier assurance programme. Technological advancements remain a focus area as we continue developing the skillsets needed to enable data flow mapping. The output will create dynamic analytics and rich data sets providing insights and intelligence whilst enhancing our reporting capabilities. We continued developing our scenario-based training modules and our employees remain engaged and committed to the fulfilment of our policy and to the wider cause.

Modern slavery and human trafficking reporting metrics

We have integrated internal controls into our controls environment and established the reporting metrics into our financial crimes framework. We have also incorporated modern slavery reporting metrics into the MLRO Annual Report received by Zellis Group board audit and risk sub-committee.

Supply chain management enhancements

During the reporting period we conducted supplier assurance in accordance with our planned schedule. Our Supplier assurance programme incorporates assessments on modern slavery and human trafficking and child labour risk exposures. We have developed the blueprint of our supply chain to understand where we may have modern slavery, human trafficking, and child labour vulnerabilities. We confirm that we have selected suppliers to lower such risk exposures and have no concerns to report. If any form of modern slavery is identified within our supply chain we would set clear requirements to provide appropriate safeguards, and establish clear reporting routes for ongoing monitoring. If necessary, we would also invoke the right to arrange for social auditing.

Next steps

We invested in specialised governance, risk, and compliance systems and tooling in 2022 to enable supply chain and data flow mapping. It will connect the end-to-end processes and third parties for all our products and services. The output will create dynamic analytics and data sets providing insights and intelligence whilst enhancing our reporting capabilities.

We continue implementing this system and will also be incorporating requirements to conduct social impact assessments where we feel it is necessary to do so. This will substantially improve the quality of visibility and oversight on standards of compliance, including our supplier assurance across all relevant jurisdictions, operating systems, networks, and infrastructure.

Training and awareness modules on modern slavery and human trafficking have been well received and the results from our call for constructive feedback have been positive. In response to that feedback, we will continue to develop our scenario-based training modules over the next financial year so that our employees remain engaged and committed to the fulfilment of our policy and to the wider cause.

Signed

John Petter – Zellis Group Chief Executive Officer

Zellis Holdings Ltd

Date: 28 August 2025

External References