Modern slavery statement

Afiniti Europe Technologies Ltd. – Modern Slavery Act Statement 2026

Financial Year: This Statement covers the financial year ending 31 December 2026 and is made pursuant to Section 54 of the UK Modern Slavery Act 2015 (the “Act”).

It applies to Afiniti Europe Technologies Ltd., its parent company Afiniti NewCo Holdings, and all subsidiaries and affiliates (collectively, “Afiniti”, “we”, “our”, or “the Company”). Afiniti NewCo Holdings is the parent company of Afiniti Europe Technologies Ltd., which is based in the United Kingdom.

Understanding Modern Slavery

Modern slavery can occur in various forms, including servitude, forced or compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty to exploit them for personal or commercial gain. This Statement’s use of the term “modern slavery” has the meaning provided in the Act.

Our Commitment

We are committed to conducting business ethically, lawfully, and transparently, and we do not tolerate any form of modern slavery or human trafficking within our operations or supply chain.

Our Code of Conduct sets out the ethical standards expected of all Afiniti employees globally and provides clear guidance on integrity, respect, and accountability.

• All employees receive a copy of the Code of Conduct upon joining and are required to sign an annual declaration confirming their understanding and adherence.
• Employees receive periodic training to ensure that these principles remain central to our culture.
• The Code outlines our expectations of suppliers and vendors, which are reinforced through supplier onboarding and due diligence processes.

Our ethical commitment forms part of Afiniti’s broader Environmental, Social and Governance (ESG) strategy and aligns with our human rights obligations under the UN Guiding Principles on Business and Human Rights.

Organizational Structure and Supply Chain

Afiniti develops and operates enterprise artificial intelligence solutions across global markets.

While our supply chain is relatively low risk compared with manufacturing or manual labour industries, we remain vigilant and expect all suppliers—direct and indirect—to share our commitment to ethical conduct and human rights.

Due Diligence and Risk Assessment

Afiniti has established processes to identify, assess, and manage modern slavery risks within our supply chain. We take the following steps:

• Conduct risk assessments to identify operations or suppliers potentially exposed to higher modern slavery risks (e.g., in certain geographies or industries).
• Include anti-slavery clauses and contractual obligations in supplier agreements, requiring compliance with the Act and Afiniti’s ethical standards.
• Request vendors and suppliers to self-certify compliance with the Act.
• Reserve the right to audit suppliers and terminate contracts where evidence of non-compliance or modern slavery is identified.
• Apply enhanced due diligence, including pre-screening and ongoing monitoring, for suppliers in higher-risk categories.

Where risks are identified, Afiniti engages directly with the supplier to ensure appropriate remediation and preventive actions.

Training and Awareness

Our Procurement, Legal, and Compliance teams receive training to recognize signs of modern slavery and to act if concerns arise.

All employees are encouraged to complete periodic modern slavery awareness training, which emphasizes:

• Identifying risk indicators.
• Reporting suspected violations.
• Conducting business with integrity and respect for human rights.

Training completion rates are tracked annually as part of our compliance monitoring program.

Measuring Effectiveness

Afiniti is committed to assessing the effectiveness of our actions. To measure progress, we monitor:

• Percentage of suppliers that have confirmed compliance with the Act.
• Percentage of employees completing Code of Conduct and modern slavery training.
• Any reported or substantiated cases of modern slavery within Afiniti or its supply chain.
• The results of supplier audits and corrective action plans.

These metrics are reviewed annually by the Compliance and ESG teams to evaluate progress and identify areas for improvement.

Reporting Concerns

Afiniti’s Reporting and Anti-Retaliation Policy provides guidance on how employees can raise concerns confidentially and without fear of reprisal.

Since September 2018, Afiniti has maintained a confidential whistleblower hotline operated by an independent provider. Employees and third parties can report concerns by:

• Contacting the hotline
• Emailing compliance@afiniti.com.

Reports may relate to:

• Suspected exploitation or human trafficking by anyone acting on behalf of Afiniti or its suppliers.
• Conduct that could violate the Act.
• Concerns that a person or organization may be preparing to engage in acts contrary to the Act.

Afiniti promptly investigates all reports, ensures cooperation from relevant parties, and takes appropriate corrective or disciplinary action when necessary.

Remediation and Safeguards

If an incident of modern slavery is identified, Afiniti is committed to ensuring remediation for affected individuals and addressing root causes in our operations or supply chain.

Corrective actions may include:

Requiring the supplier to take immediate corrective steps.

• Providing or facilitating access to victim support where appropriate.
• Terminating contracts with suppliers unwilling or unable to meet required standards.
• Implementing preventive measures to reduce future risk.

Future Commitments

Looking ahead, Afiniti will:

• Continue enhancing our risk assessment and supplier engagement processes.
• Publish future statements on the UK Government’s Modern Slavery Statement Registry once mandatory.
• Review this Statement annually and update our training and due diligence practices as required.

This Statement has been approved by the Board of Directors of Afiniti Europe Technologies Ltd.