Anti-Slavery Policy

Organization

This statement applies to all companies within and associated to Macfarlane Media
Limited (referred to in this statement as “The Group”). The information included in the
statement refers to the financial year 2025.

Definitions

The Group considers that modern slavery encompasses:
human trafficking

• forced work, through mental or physical threat
• being owned or controlled by an employer through mental or physical abuse
  or the threat of abuse
• being dehumanized, treated as a commodity or being bought or sold as
  property
• being physically constrained or having a restrictions placed on freedom of
  movement.

Commitment

The Group acknowledges its responsibilities in relation to tackling modern slavery
and commits to complying with the provisions in the Modern Slavery Act 2015. The
Group understands that this requires an ongoing review of both its internal practices
in relation to its labor force and, additionally, its supply chains.
The Group does not enter into business with any other organization, in the United
Kingdom or abroad, which knowingly supports or is found to involve itself in slavery,
servitude and forced or compulsory labor.

No labor provided to the Group in the pursuance of the provision of its own services
is obtained by means of slavery or human trafficking. The Group strictly adheres to
the minimum standards required in relation to its responsibilities under relevant
employment legislation in the Unuted Kingdom, Unites States of America, Europe,
Asia, and South Africa, [and in many cases exceeds those minimums in relation to its
employees].

Organizational structure

In general, the Group considers its exposure to slavery/human trafficking to be
relatively limited. Nonetheless, it has taken steps to ensure that such practices do
not take place in its business nor the business of any organization that supplies
services to it.

Due diligence in relation to modern slavery

The Group carries out due diligence processes in relation to ensuring slavery and/or
human trafficking does not take place in its organization or supply chains, including
conducting a review of the controls of its suppliers.

Training

The Group provides training to staff to effectively implement its stance on modern
slavery, and each member has access to the Group’s modern slavery policies.
Monitoring and evaluation
The Group constantly monitors and evaluates its effectiveness in ensuring modern
slavery is not taking place in the Group or its supply chains.

Steps

The Group has not, to its knowledge, conducted any business with another
organization which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Group has
taken the following steps to ensure that modern slavery is not taking place:

• reviewing supplier contracts to incorporate termination rights in cases where
  the supplier is involved in, or suspected of being involved in, modern slavery
• Added clauses to all client contracts to include the Group’s non-tolerance for
  slavery and human trafficking, providing termination powers if the client is, or
  is suspected to be, involved in modern slavery
• measures in place to identify and evaluate the potential risks in its supply
  chains
• training provided to staff on modern slavery.

Modern slavery compliance officer

The Group has a modern slavery compliance officer, to whom all concerns regarding
modern slavery should be addressed, and who will then undertake relevant action
with regard to the Group’s obligations.
This statement is made in pursuance of s.54(1) of the Modern Slavery Act 2015 and
will be reviewed for each financial year.