Modern Slavery Statement

This statement was last reviewed on: 20 May 2025.

Kocho’s Commitment

Kocho is committed to operating ethically and honestly in all its business dealings and takes a zero tolerance approach to any form of modern slavery or human trafficking. We are fully committed to preventing slavery and human trafficking in our operation and supply chain focusing on the following objectives:

• Ensuring that consideration of modern slavery risks and prevention are added to key policy review processes as an employer and procurer of goods and services.
• Ensuring that all employees, including those involved in buying/procurement and the recruitment and deployment of workers, receive training on modern slavery and ethical employment practices.
• Providing awareness training to employees on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking.

Organisation Structure and Supply Chains

We establish a relationship of trust and integrity with all our suppliers. Our supplier onboarding and ongoing review processes include due diligence of a supplier’s reputation, ethics, security and compliance with regulatory standards.

To date, we have not been made aware of any allegations of human trafficking/slavery activities against any of our suppliers but if we were, would take robust action against that supplier.

Organisational Policies

To demonstrate compliance with the legal requirements of the Modern Slavery Act, Kocho does the following:

• We update this Modern Slavery Policy at the start of each financial year and the Policy is made available to all employees via the Kocho intranet.
• The Modern Slavery Policy is approved by the Board of Directors and signed off by a member of the Kocho Executive Board.
• We also publish this Modern Slavery Statement.

The following documents are in place to support employees in the reporting of any concerns:

• Employee Code of Conduct: The Kocho code of conduct encapsulates the three values of ‘Do what’s right’, ‘Think greater’ and ‘Better together’ and encourages our employees to exhibit the highest standards of conduct and ethical behaviour when representing our company or managing our supply chain.
• Whistleblowing Policy: Kocho is committed to ensuring that no employee will suffer any repercussions from reporting any suspicion of slavery or human trafficking. To this end, the Whistleblowing Policy is available to all employees and details how they can report any suspicions without fear of retaliation.
• Supplier Code of Conduct: Kocho’s Supplier Onboarding Process makes specific reference to slavery and human trafficking, and requires our suppliers to commit to the same high standards of conduct and behaviour that we expect of our employees. Kocho does not do business with suppliers who cannot commit to such an undertaking.
• ESG Policy: The Environmental, Social and Governance Policy available to all employees and to clients on request details the underlying principles governing how Kocho operates.

Assessing and Managing Risk

Risks associated with modern slavery are managed via the Kocho risk management framework, which helps determine our response and the controls that we implement.

Where an employee suspects an instance of slavery or human trafficking, they must immediately report it to their Line Manager, the Head of Governance & Sustainability or a member of the Senior Leadership Team.

Supplier Due Diligence in Relation to Modern Slavery

Kocho’s Supplier Onboarding Process makes specific reference to slavery and human trafficking in the due diligence questionnaire submitted to potential new suppliers. Due diligence in this area is also part of the ongoing reviews of our existing suppliers.

In particular, we ask our key suppliers to attest that:

• They don’t use any form of forced, compulsory or slave labour;
• Their employees work voluntarily and are entitled to leave work;
• Each employee is provided with an employment contract that contains a reasonable notice period for terminating their employment;
• Employees are not required to post a deposit/bond and their salary is not withheld for any reason;
• Employees are not required to surrender their passports or work permits as a condition of employment with that supplier.

Awareness and Training

Our Modern Slavery Policy is available to all Kocho employees who must familiarise themselves with its contents. Awareness of this Policy forms part of the induction training received by each new employee to Kocho.

All employees receive a training course on modern slavery as part of their annual training programme.

Monitoring and Evaluation

The following improvement areas have been identified as part of Kocho’s monitoring and evaluation of its response to this subject:

1. Although the Supplier Onboarding Process already contains questions around modern slavery, we recognise that the breadth of these questions could be expanded and strengthened to improve onboarding due diligence.
2. The ongoing supplier review process could also be further improved. To achieve this, an analysis will be conducted of all existing suppliers to ensure that the same level of due diligence has taken place across the board, and steps will be taken to clarify and obtain assurances from these suppliers as to their policy and the actions they are taking to protect against modern slavery.
3. Kocho will be introducing steps to ensure 100% compliance from its employees in the completion of their modern slavery training, through the use of a KPI placed on each employee.
4. Outcome focused business KPIs will also be introduced to measure progress towards these improvements.
5. Kocho will also look to fully align with the Organisation for Economic Co-operation and Development (OECD) and UN Guiding Principles (UNGP) guidelines as part of its wider ESG strategy.