Modern Slavery

ICF Holdings Ltd, a limited company registered in England and Wales with company number 11777140, and registered office at C/O UHY Hacker Young, Bradbury House, Mission Court, Newport, South Wales, NP20 2DW, together with the other constituent members set out below, trades as and is part of the Indigo Group (the “Group”).

We are proud of the steps we have taken to combat slavery and human trafficking.

This statement reflects the steps taken to date and constitutes the Group’s slavery and human trafficking statement for the financial year ending in September 2025. It was approved by the Board of Directors on, and has been signed off by Ian Cole Wilkins, Group CEO on 23/03/2026

Our supply chains primarily consist of:
• End clients to whom we provide services
• The relevant group company delivering those services
• Umbrella employees, self-employed contractors, and limited companies engaged on behalf of end clients
We have not identified operations within high-risk countries where modern slavery is prevalent.

We are committed to ensuring that modern slavery and human trafficking do not occur within our business or supply chains.
Our Right to Work policy and broader anti-slavery and human trafficking policies reflect our commitment to acting ethically, with integrity, and to implementing and enforcing effective systems and controls.
We maintain a whistleblowing policy, accessible to all staff, with clear reporting channels should any concerns arise.

Our bespoke supply chain platform utilises Credas Technologies Ltd DIATF-certified technology and performs multiple checks to prevent slavery and human trafficking within our supply chain. These include:
• Know Your Customer (KYC) checks
• Right to Work verification for all involved parties
• Address and Anti-Money Laundering (AML) checks
• Bank validation checks

We maintain a zero-tolerance approach to slavery and human trafficking.
To ensure compliance, we operate a robust supplier compliance programme, including a registration and review process that utilises multi-point checks to identify potential risks.
Compliance remains a standing agenda item at Senior Management Team (SMT) meetings, with representatives from all departments. The Operations and Compliance Departments are responsible for addressing any identified issues.

To ensure a high level of understanding of modern slavery risks, we:
• Provide mandatory training to all staff
• Reference this policy within our Staff Handbook
• Require business partners to provide training to their staff and supply chains
• Keep up to date with Government requirements and legislative changes

We conduct full induction training for new staff, with annual refresher sessions and updates reflecting changes in legislation and best practice (including digital Right to Work requirements).

Following a review of the effectiveness of our approach, we will:
• Continue to verify at least 98% of our supply chain through the Indigo platform and using Credas Technologies Ltd
• Strengthen supplier monitoring and audit processes
• Enhance employee awareness and external engagement to promote ethical labour standards

This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015.

Signed: