Modern Slavery

ICF Holdings Ltd, a limited company registered in England and Wales with the 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 in paragraph 1 below, It trades as and is part of the Indigo Group described below (hereinafter the “Group”).

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

The statement reflects the steps that we have taken to date and constitutes our Group’s slavery and human trafficking statement for the financial year ending in 2024. It was approved by our board of directors in a board meeting held on 20/03/2024 and has been signed off by Ian Cole Wilkins, Group CEO also on 25/03/2024.

The supply chains that we are primarily operating within consist of: our end clients that we provide our services to; the relevant group company that provides the services; and either our umbrella employees, self- employed contractors or limited companies that we provide our services to or for on behalf of end clients.

We have not been involved with any high risk countries where modern forms of slavery are prevalent.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Right to Work policy and other anti-slavery and human trafficking policies reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls. We also have a documented whistle blowing policy which all staff have access to and clear lines of reporting, should any process highlight issues in this area.

Our bespoke supply chain platform uses Credas DIATF certified technology and performs several checks to ensure slavery and human trafficking is not taking place anywhere in our supply chain. These include Know Your Customer checks, Right to Work checks for all in the chain, address checks, Anti-Money Laundering checks and bank checks, using digital identity verification process and our cloud-based technology.

We have zero-tolerance for slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values and ethics we have in place a rigorous supply chain compliance programme. This consists of a registration and review process utilising multi-point checks to pick up potential discrepancies that might be indicative of a slavery risk.

Compliance is a standing item on our Senior Management Team’s (SMT) meeting agenda with representation from all departments across the Group. Representatives from the Operations Department and Legal Department are specifically tasked with addressing compliance issues that are identified via SMT.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have and continue to provide training to our staff and the policy is expressly referenced in our Staff Handbook. We also require our business partners to provide training to their staff and suppliers and providers.

We provide staff training and understanding on start with full induction around requirements and perform annual refreshers or update sessions when there are changes within legislation and practice such as the recent introduction of share code use and checking. Our registration and supply chain platform allows us to standardise changes and ensure that current responsibilities are met, and staff are guided through these in the use of this software.

Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains, we intend to progress to verify at least 90% of our supply chain through our digital Indigo platform registration software utilising technology provided by Credas Technologies Ltd to ensure that we are taking the utmost care in carrying out the due diligence process to combat slavery and human trafficking.

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

Signed