INTRODUCTION

This policy is made on behalf of Valcon Group UK and is informed by section 54(1) of the Modern Slavery Act 2015 and comprises our slavery and human trafficking statement.

Valcon is not obliged under legislation to set out a Modern Slavery statement (as the company falls below the thresholds under which one is obligated), however the company still publishes this statement as:

• Many of the client organisations with which we work are obliged to publish a statement, and routinely enquire as to our position
• We support the principles of the Act and therefore seek to act within the spirit of the law rather than simply comply with the minimum obligations.

This policy should be read in conjunction with associated policies, and in particular:

• Recruitment
• Whistleblowing
• Company Values and Professional Standards.

POLICY STATEMENT

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR THE FINANCIAL YEAR 2025.

This statement is made on behalf of Valcon.

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.

Our Business

Valcon is one of the world’s fastest growing consultancies, and delivers premium operations consulting merged with deep technology and data expertise.

We we have the full range of capabilities and expertise that our clients need to give them a competitive advantage through people, processes, data and technology. We weave these skills together in different ways to respond to new opportunities and challenges that deliver sustainable results.

We are headquartered in the Netherlands with operations within the UK, Denmark, Sweden, Germany, Croatia and Serbia, and services delivered internationally when required. As a consultancy within the professional services sector, it is not the view of the company that it operates in any markets or services that are likely to be considered high-risk.

Statement

This Policy Statement affirms the commitment of Valcon to acting ethically and with integrity in all its business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking does not take place anywhere within its business and supply chains.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

The Valcon Group UK Managing Partner is nominated to provide planning to identify risk and mitigate against such risks. The UK Managing Partner, in turn will work with others (notably within human resources, recruitment, and operations/commercial functions) and report, as needed to the Company Board.

Our scrutiny and planning will specifically:

• Identify inappropriate employment practices
• Mitigate the risk of slavery and human trafficking occurring within the business and the company supply chain
• Identify, assess and monitor other potential risk areas
• Protect whistle-blowers.

SUPPLIER ADHERENCE TO ANTI-SLAVERY AND HUMAN TRAFFICKING

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with this policy we operate in line with principles of responsible sourcing, including:

• Ensuring employees are paid within the boundaries of the company’s pay policies, and which in all cases exceed the prevailing minimum wage levels applicable under legislation
• Ensuring employees work hours and benefit from holidays that all cases comply with the requirements under the Working Time Regulations
• Review the company supply chain, through the tender process, supplier reviews, and self-certification declarations, to ensure compliance with the requirements of this policy.

CLIENT ADHERENCE TO ANTI-SLAVERY AND HUMAN TRAFFICKING

Valcon is committed to only work for client organisations that support the principles of the Modern Slavery Act.

Valcon commits not to work with any organisation where there are breaches, or grounds to suspect breaches, of the Act.

POLICY AND PROCEDURE

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, in our supply chains and in our business partners, we operate a clear policy and procedure that is set out in our company policies manual.

This policy amongst other forms part of the Induction Training Process and communications within our Employee Handbook, Manager Guide, and within our Intranet.

DECLARATION

This Policy Statement has been updated since the original publication in May 2022 and applies for the financial year ending 31st December 2025.