MODERN SLAVERY ACT 2015: SLAVERY AND HUMAN TRAFFICKING STATEMENT

This statement has been published in accordance with Section 54 of theModern Slavery Act 2015.  It outlines themeasures that we have taken at Delivery Associates to ensure that no slavery orhuman trafficking is present in our business our supply chains.

1. Board statement

1.1. DELIVERY ASSOCIATES is committed to the highest standards of ethical conduct
across our global operations. We are committed to preventing, identifying and addressing
modern slavery risks, forced labour, servitude, child labour, and human trafficking in any
for whether within our own business or in the supply chains through which we deliver
services to our clients.

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1.2. As a global provider of social impact consultancy to the public sector, operating across 40
countries and employing more than 300 people, we recognise that our geographic
footprint and supply chain complexity carry inherent risk. We take that responsibility
seriously. This statement describes, in concrete terms, the structures, policies, due
diligence processes, and performance metrics we have put in place to identify, prevent,
and remediate modern slavery risk.

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1.3. This statement has been approved by the Board of Directors of DELIVERY
ASSOCIATES Limited and covers the DELIVERY ASSOCIATES group for the financial
year ending 31st December 2025. It is published in compliance with section 54(1) of the
Modern Slavery Act 201

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2. Governance and Accountability

2.1. Responsibility for overseeing DELIVERY ASSOCIATES’s approach to modern slavery
rests with the Board of Directors. The Board receives periodic reports regarding ethical
compliance, supply chain risks, whistleblowing matters and human rights concerns, and
is responsible for reviewing the effectiveness of the controls established to mitigate
modern slavery risks.

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2.2. Day-to-day responsibility for implementation of this policy framework is delegated to
senior management, supported by relevant operational, procurement, legal and human
resources personnel.

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2.3. Our governance framework is designed to ensure that:
2.3.1. modern slavery risks are identified and assessed;
2.3.2. concerns are escalated promptly;
2.3.3. appropriate remedial actions are implemented where required; and
2.3.4. continuous improvements are made to our policies and procedures.

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3. Human Rights Commitment

Our approach to modern slavery is built with reference to the following international human rights
standards:
3.1. Standards:
3.1.1. United Nations Guiding Principles on Business and Human Rights.
3.1.2. International Labour Organisation (ILO) Core Conventions.
3.1.3. Universal Declaration of Human Rights.

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4. Organisation Structure and Business

4.1. Group Structure

The DELIVERY ASSOCIATES group comprises the following entities:
DELIVERY ASSOCIATES Limited (UK)
DELIVERY ASSOCIATES Ltd (US)
DELIVERY ASSOCIATES Australia Pty Ltd
DELIVERY ASSOCIATES Brazil
DELIVERY ASSOCIATES Peru‍

4.2. Nature of Our Business

DELIVERY ASSOCIATES is a global provider of social impact consultancy services to public
sector clients. We design and deliver advisory, programme management, and implementation
support services across health, education, governance, and economic development. Our
client base spans central government departments, international institutions, development
finance organisations, and multilateral bodies

4.3. Geographic Footprint

We operate in 40 countries across Europe, North America, Asia, Africa, and the Middle East.
Our workforce includes directly employed staff, associates, and subcontracted specialists,
reflecting the project-based nature of our work. This international footprint means that some of
our operations and supply chain relationships fall within jurisdictions that may carry elevated
modern slavery risk.

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5. Our Supply Chains

Our principal supply chain categories are as follows:

5.1. Technology and software services — including platform providers, data analytics
suppliers, and managed IT services;

5.2. Professional and consulting services — including specialist subcontractors, independent
associates, and research partners engaged on project delivery;

5.3. Event management and logistics — including venue management, audio-visual,
hospitality, and travel providers; and

5.4. Corporate services — including facilities management, HR services, and professional
advisers;
5.5. Recruitment and staffing agencies — engaged in connection with permanent, temporary
and contract hiring;

5.6. Travel and accommodation providers — including airlines, hotels and ground
transportation suppliers; and

5.7. Research, data collection and administrative support providers — including survey and
field research partners and business process support suppliers.

Our supply base has a global reach. Suppliers and subcontractors operating in less-regulated
markets, or in regions with elevated labour risk, are subject to enhanced due diligence as
described in Section 7 below.

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6. Policies Relevant to Modern Slavery

We maintain the following policies that directly address modern slavery and related risks:

6.1. Anti-Slavery and Human Trafficking Policy - sets out our zero-tolerance position, defines
relevant terms, and establishes reporting and escalation obligations for all staff.

6.2. Code of Business Conduct and Ethics - sets out the standards of behaviour expected of
all DELIVERY ASSOCIATES personnel and business partners, including compliance with
applicable human rights and labour laws.

6.3. Supplier Code of Conduct - requires all suppliers to comply with applicable labour laws,
prohibits the use of forced or compulsory labour, child labour, and human trafficking, and
requires suppliers to cascade equivalent obligations through their own supply chains.

6.4. Whistleblowing Policy - provides confidential reporting channels for employees and third
parties to raise concerns about modern slavery or unethical labour practices, with an
express prohibition on retaliation against individuals who raise concerns in good faith.

6.5. Recruitment and Employment Policy - governs direct employment and engagement
practices, including right-to-work checks, written contracts, and verification that pay and
working conditions meet applicable legal standards.

6.6. Procurement Policy - requires modern slavery due diligence as a mandatory step in the
supplier onboarding process.

All policies are reviewed annually and approved by the Board. Material updates are
communicated to all staff.

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7. Due Diligence Processes

7.1. Risk Assessment

We conduct a structured risk assessment of modern slavery exposure across our operations
and supply chains. Our assessment framework considers three primary risk dimensions:

7.1.1. Geographic risk - we map our operational and supply chain footprint against
internationally recognised indices of labour standards, governance quality, and rule
of law, including the Global Slavery Index, Transparency International’s Corruption
Perceptions Index, and the International Labour Organisation’s indicators of forced labour. Regions where we assess material risk are designated as requiring enhanced due diligence.

7.1.2. Sectoral and service risk - outsourced and subcontracted services, particularly in
lower-regulated markets, carry inherently higher risk. We apply heightened scrutiny
to consulting and technology subcontracts in such regions.

7.1.3. Labour practice risk - the use of contingent workers, temporary consultants, and
local subcontractors in international project settings is a recognised vector for
unethical labour practices, and is subject to additional oversight.
Our current risk assessment is summarised in the table at Section 7.2 below.

7.2. Risk Register

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7.3. Supplier Due Diligence

All new suppliers are subject to a structured vetting process prior to engagement. This
includes:

7.3.1. Completion of a supplier questionnaire covering labour practices, sub-contracting
arrangements, and relevant policies;

7.3.2. Verification of compliance with applicable employment laws in the relevant
jurisdiction;

7.3.3. Review of the supplier’s own modern slavery policy (where applicable under local
law or good practice standards);

7.3.4. Risk-tiering of the supplier, with enhanced diligence applied to higher-risk
engagements; and

7.3.5. Inclusion of mandatory contractual provisions (see Section 7.4 below).

Existing suppliers in higher-risk categories are subject to periodic re-screening, no less frequently
than every two years. Any supplier that fails to meet our standards is not engaged, or where an
existing supplier relationship is found to be non-compliant, engagement is suspended pending
remediation or terminated.

7.4. Contractual Protections

All supplier and subcontractor agreements include provisions that:

7.4.1. Prohibit the use of forced, compulsory, or trafficked labour, or the engagement of
anyone held in slavery or servitude;

7.4.2. Require compliance with all applicable anti-slavery and labour laws in the relevant
jurisdiction;

7.4.3. Require the supplier to cascade equivalent obligations to its own subcontractors
and suppliers;

7.4.4. Require prompt notification to DELIVERY ASSOCIATES of any known or
suspected instance of modern slavery in the supply chain; and

7.4.5. Permit DELIVERY ASSOCIATES to audit or request evidence of compliance, and
to terminate on material breach.

7.5. Employee and Workforce Protections

For all directly employed staff:

7.5.1. Every employee is provided with a written contract prior to commencement of
employment;

7.5.2. Right-to-work verification is conducted for all employees in every jurisdiction;

7.5.3. Pay, hours, and working conditions are verified against applicable legal minima;

7.5.4. No fees are charged to workers in connection with recruitment or placement; and

7.5.5. Workers are free to leave employment on notice and retain control of their identity
documents.

7.6. Reporting and Escalation

We maintain accessible, confidential reporting channels through which employees, suppliers,
and other third parties can raise concerns about modern slavery or unethical labour practices.
Reports are investigated promptly. Where a report identifies credible risk of modern slavery, it
is escalated to the legal and, as appropriate, to the Board. We maintain a strict non-retaliation
policy.

7.7. Ongoing Monitoring

We continue to monitor supplier relationships on an ongoing basis and remain alert to
indicators of labour exploitation through our procurement, contract management and
operational processes. This includes periodic review of higher-risk supplier relationships,
assessment of supply chain changes that may affect risk exposure, and monitoring of
developments in the jurisdictions in which we operate.

Where concerns are identified through monitoring activities, they are investigated promptly
and escalated through appropriate management and governance channels in accordance
with our due diligence framework.

7.8. Remediation and Corrective Action

Where DELIVERY ASSOCIATES identifies actual or suspected modern slavery, we will take
appropriate remedial action proportionate to the circumstances. Such action may include
supplier corrective action plans, suspension of engagements, termination of contracts,
notification of relevant authorities, and appropriate support for affected individuals.

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8. Training and Awareness

All DELIVERY ASSOCIATES staff receive modern slavery training as follows:

8.1. Induction training - all new employees complete mandatory modern slavery and human
trafficking awareness training as part of their induction programme. Completion is tracked
and is a condition of confirming employment.

8.2. Refresher training - all employees complete a refresher module every two years. Content
is updated to reflect material changes in law, guidance, or risk environment.

8.3. Specialist training - procurement, HR, and legal staff receive additional role-specific
training covering supplier vetting, contractual obligations, and escalation protocols.

8.4. Management training - people managers receive guidance on identifying and responding
to potential indicators of exploitation in the workforce.

Training materials are reviewed annually by the legal.

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Measuring Effectiveness

We measure the effectiveness of our anti-slavery programme through the following key
performance indicators.

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8.5. In the financial year 2025, no instances of modern slavery were identified within
DELIVERY ASSOCIATES's direct operations. No substantiated instances were identified
through our supplier due diligence and monitoring activities during the reporting period.
No concern report was received through our whistleblowing portal.

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Board Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. It constitutes
the slavery and human trafficking statement of the DELIVERY ASSOCIATES group for the
financial year ending 2025.

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Didier Faure

Member of the Board