Modern Slavery & Human Trafficking Statement

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that have been taken during the previous financial year to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

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. This statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Our organisation operates within the recruitment and human capital advisory sector. Our group comprises the following trading entities:

• HPG Advisory Services – Executive search and human capital advisory
• Madison Mayfair – Finding and attracting key players globally
• FM Recruitment – Specialist hospitality finance recruitment

We operate primarily in the UK and internationally, providing recruitment services to the hospitality and leisure sectors.

Our supply chain includes suppliers of IT services, office supplies, professional services, and other operational support. We conduct due diligence on new suppliers and regularly review our existing suppliers.

We expect all suppliers to comply with our values and ethics and to operate in accordance with relevant laws and regulations. We require suppliers to confirm that they:

• Do not use any form of forced, compulsory, or trafficked labour
• Ensure that their employees work voluntarily and are entitled to leave work
• Provide each employee with a written contract of employment
• Do not require employees to pay any recruitment fees
• Ensure that wages meet legal minimum requirements

We have a number of policies which help to ensure that we operate in an ethical and transparent manner. These include:

• Staff responsibilities – All employees are expected to report concerns relating to any issue or suspicion of modern slavery
• Code of conduct – Establishes the manner in which we behave as an organisation and how we expect our employees and suppliers to act
• Anti-discrimination policy – We are committed to ensuring there is no discrimination in our recruitment processes
• National Minimum/Living Wage compliance – We ensure all employees are paid above the National Minimum Wage
• Right-to-work verification – We verify the identity and right to work of all employees before employment commences

As part of our initiative to identify and mitigate risk, we undertake due diligence when considering taking on new suppliers. We also review our existing suppliers on a regular basis.

Our due diligence and reviews include:

• Mapping the supply chain to assess particular product or geographical risks of modern slavery and human trafficking
• Evaluating the modern slavery and human trafficking risks of each new supplier
• Reviewing supplier policies and procedures to ensure they have suitable anti-slavery and human trafficking policies in place

The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

We ensure that all employees are aware of the risks of modern slavery and human trafficking and what to do if they suspect it is taking place within our supply chain or business.

We provide training to relevant employees on how to identify and report signs of modern slavery and human trafficking. Our communication includes:

• Regular communication to all staff about our zero tolerance approach to modern slavery
• Guidance on identifying potential signs of forced labour or exploitation
• Clear reporting procedures for any concerns

We take a zero tolerance approach to modern slavery and human trafficking. Where we find evidence of breaches of this policy:

• Employees who breach this policy will face disciplinary action, which may result in dismissal for misconduct or gross misconduct
• We may terminate our commercial relationships with suppliers if they are found to be in breach of this policy
• Where appropriate, we will report any concerns to the relevant authorities

This statement is made for the financial year ending 31 December 2025 and will be reviewed and updated annually.

This statement has been approved by the Board of Directors of Hospitality People Group Ltd.