Legal

Policy Owner	People & Operations
Approved By	Board of Directors
Version	1.0
Effective Date	February 2026
Review Date	February 2027
Applies To	All Beauhurst employees, contractors, and suppliers

1. Introduction and Purpose

Beauhurst is committed to acting ethically and with integrity in all our business dealings and relationships. We are committed to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere in our own business or in any of our supply chains.

This policy sets out our approach to identifying, preventing and responding to the risks of modern slavery, forced labour, and human trafficking. It applies to all persons working for or on behalf of Beauhurst, in any capacity, including employees, directors, officers, agency workers, contractors, and suppliers.

Beauhurst is a UK-based technology and data company. As an organisation providing data, analytics, and intelligence services, our direct exposure to the most severe forms of modern slavery in physical supply chains is limited; however, we recognise that risks exist in our extended supply chains and in the digital economy, and we take those risks seriously.

2. Legal and Regulatory Framework

This policy has been developed in compliance with the following legislation and guidance:

• Modern Slavery Act 2015 (UK) — which requires businesses with an annual turnover of £36 million or more to publish an annual Transparency Statement
• Home Office guidance on the Modern Slavery Act 2015
• UN Guiding Principles on Business and Human Rights
• International Labour Organization (ILO) fundamental conventions
• UK Government’s Modern Slavery Strategy

Even where statutory reporting thresholds do not apply, Beauhurst voluntarily commits to the principles of this policy as a matter of good corporate governance and ethical responsibility.

3. What Is Modern Slavery?

Modern slavery is a serious crime and a grave violation of fundamental human rights. It takes several forms, all of which deprive victims of their liberty for personal or commercial gain. Beauhurst recognises and seeks to prevent the following forms:

3.1 Forms of Modern Slavery

• Forced or compulsory labour — work extracted from a person under threat of penalty, where they have not offered themselves voluntarily
• Human trafficking — the recruitment, transportation, transfer, harbouring or receipt of people by means of threat, force, coercion or deception for exploitation
• Debt bondage — where a person is forced to work to pay off a debt and cannot reasonably pay it back
• Child labour — any work that deprives children of their childhood, potential and dignity, and that is harmful to their physical and mental development
• Domestic servitude — where victims are forced to work in private households under exploitative conditions
• Sexual exploitation — the abuse of a position of power to coerce a person into sexual activity
• Criminal exploitation — where individuals are forced to commit crimes for the benefit of others

4. Our Business and Supply Chains

4.1 Our Business Model

Beauhurst provides data, research, and intelligence products and services to financial institutions, professional services firms, investors, and government bodies. Our operations are primarily office-based and our workforce is employed directly or engaged on formal contractual terms.

Our workforce is international in scope. In addition to our UK-based employees, we have staff and contractors located in India, Berlin (Germany), Canada, and South America. All engagements are subject to formal contractual arrangements. Visa sponsorship for overseas workers is managed directly and internally by Beauhurst, ensuring that workers are not exposed to third-party recruitment fees or debt bondage risks associated with sponsored migration.

4.2 Outsourced Operations

Beauhurst engages two long-standing India-based outsourcing providers to support our data operations:

• AMR — through whom 31 outsourced workers are currently engaged
• Growth Hub — through whom 11 outsourced workers are currently engaged

Both relationships have been in place for more than seven years and are governed by formal written service agreements. These agreements include provisions requiring compliance with applicable employment law, ethical labour practices, and the prohibition of forced or child labour. Beauhurst engages with both providers on an ongoing basis and will seek periodic reconfirmation of their compliance with these obligations.

4.3 Third-Party Data and API Providers

Beauhurst relies on a number of third-party data and API providers as part of our data infrastructure and product development. Our current providers include:

• Vistra
• BuiltWith
• Patstat
• Companies House Filing API
• ClearBit
• Norbert
• CCJ
• Creditsafe
• CurrencyLayer
• OpenExchangeRate

These providers are predominantly technology and data businesses. Whilst their direct modern slavery risk profile is considered lower than physical supply chains, we include them in our supplier review processes and expect them to operate to equivalent ethical standards.

4.4 Recruitment Agencies

Beauhurst uses reputable recruitment agencies to support talent acquisition. Our current agency relationship is with Rocking Zebra. In the preceding 12 months we have also engaged Salesamp (formerly Unicorn, previously Wiser), Zetter, Grotech, and Purpose Collective.

We do not permit recruitment agencies to charge fees to candidates or workers as a condition of placement. All agencies used by Beauhurst are expected to comply with this requirement and with applicable employment and anti-slavery legislation.

4.5 Other Supply Chain Categories

Our broader supply chain also includes:

• Software, cloud, and infrastructure vendors (e.g. cloud hosting, CRM, and communication platforms)
• Professional services providers (e.g. legal, accounting, and HR advisory)
• IT hardware and equipment suppliers
• Facilities and office service providers

We acknowledge that technology supply chains, including hardware manufacture and lower-tier software development, can carry modern slavery risk. We are committed to applying due diligence proportionate to the risk profile of each supplier relationship.

5. Risk Assessment and Due Diligence

5.1 Risk Identification

Beauhurst conducts periodic risk assessments to identify potential modern slavery risks within our business and supply chains. Risk factors we consider include:

• Geographic risk — suppliers or sub-contractors operating in higher-risk jurisdictions
• Sector risk — industries with documented histories of labour exploitation (e.g. electronics manufacturing, cleaning and facilities services)
• Worker vulnerability — use of temporary, migrant or agency workers
• Pricing pressure — supply contracts where abnormally low pricing may indicate labour exploitation
• Recruitment practices — whether recruitment fees or other costs are passed on to workers

5.2 Supplier Due Diligence

We apply a risk-based approach to supplier due diligence. This includes:

• Incorporating modern slavery and ethical trading requirements into supplier onboarding processes and standard contract terms
• Requiring key suppliers to confirm compliance with the Modern Slavery Act 2015 (where applicable) and equivalent legislation
• Conducting supplier questionnaires and, where appropriate, audits or third-party assessments
• Reviewing supplier transparency statements where publicly available
• Escalating concerns where a supplier is unable to demonstrate adequate modern slavery controls

5.3 Internal Controls

Within our own operations, we maintain controls including:

• Compliance with UK employment law, including National Minimum Wage and National Living Wage requirements
• Formal employment contracts for all employees and written agreements for contractors
• Identity and right-to-work verification for all staff prior to engagement
• Visa sponsorship managed internally by Beauhurst to ensure workers are not subject to third-party recruitment fees or exploitative migration arrangements
• Use of reputable recruitment agencies who are required to confirm that no fees are charged to candidates
• Accessible reporting mechanisms for raising concerns (see Section 8)

6. Roles and Responsibilities

Responsibility for implementing this policy is shared across the organisation:

6.1 Board of Directors

The Board has overall responsibility for ensuring this policy complies with our legal and ethical obligations. The Board reviews and approves this policy and Beauhurst’s annual Modern Slavery Transparency Statement (where required).

6.2 Senior Leadership Team

Senior leaders are responsible for ensuring that modern slavery risks are considered in business decisions, supplier relationships, and operational planning, and for fostering a culture of transparency and ethical conduct.

6.3 People and Operations Function

The People & Operations team is responsible for implementing this policy, maintaining due diligence processes, conducting training, and managing the reporting and escalation of concerns.

6.4 All Employees and Contractors

All individuals working for or on behalf of Beauhurst are required to read, understand, and comply with this policy. Everyone has a responsibility to be alert to the signs of modern slavery and to report concerns promptly.

7. Training and Awareness

Beauhurst is committed to ensuring that all staff have sufficient knowledge and training to identify modern slavery and human trafficking risks. Our approach includes:

• Mandatory awareness training for all new employees as part of induction
• Periodic refresher training for existing employees, particularly those involved in procurement, HR, and supplier management
• Specific guidance for managers on identifying and responding to signs of exploitation
• Communication of this policy to all relevant contractors and suppliers

Training content covers: what modern slavery is and how to recognise it; how to raise concerns; Beauhurst’s reporting procedures; and relevant legal obligations.

8. Reporting Concerns

8.1 Internal Reporting

We encourage all employees, contractors, and suppliers to raise concerns about any issue or suspicion of modern slavery as soon as possible. Concerns can be raised with:

• Your line manager or a member of the People & Operations team
• A member of the Senior Leadership Team

8.2 Raising Concerns — Current Arrangements

Beauhurst does not currently have a standalone formal whistleblowing policy. Employees and contractors are encouraged to raise any concerns about modern slavery, labour exploitation, or related ethical issues directly with a member of the People & Operations team or a member of the Senior Leadership Team. All concerns raised will be taken seriously, handled with discretion, and investigated promptly.

Beauhurst will not tolerate any retaliation or adverse treatment of any person who raises a concern in good faith. The introduction of a formal whistleblowing policy is identified as a priority action for Beauhurst’s governance development programme.

8.3 External Reporting

Employees can also report concerns externally to:

• The Modern Slavery Helpline: 08000 121 700 (free, 24/7)
• The Gangmasters and Labour Abuse Authority (GLAA)
• The National Crime Agency (NCA)
• The police (999 in an emergency; 101 for non-emergency)

9. Transparency Statement

Where Beauhurst meets the turnover threshold set out in the Modern Slavery Act 2015, we will publish an annual Modern Slavery and Human Trafficking Transparency Statement, approved by the Board, setting out the steps taken during the financial year to prevent modern slavery in our business and supply chains. This statement will be made available on our website.

Even in years where the statutory threshold is not met, we commit to publishing a voluntary statement as part of our broader commitment to transparency and responsible business practice.

10. Breaches of This Policy

Any employee found to have violated this policy may be subject to disciplinary action, up to and including summary dismissal for gross misconduct. Contractors or suppliers found to be in breach may have their engagement terminated.

Where Beauhurst discovers or suspects that modern slavery is occurring within its own operations or supply chain, we will take immediate steps to investigate and, where appropriate, report to relevant authorities and support any victims identified.

11. Policy Review

This policy will be reviewed annually by the People & Operations function, or sooner in response to changes in law, business structure, or identified risks. All material updates will be approved by the Board prior to adoption.

This policy was last reviewed and approved in February 2026.

12. Related Policies and Governance Development

Beauhurst recognises that this Modern Slavery Policy sits within a broader framework of ethical governance. At the time of adoption, Beauhurst does not have formal standalone policies in place covering whistleblowing, anti-bribery and corruption, ESG, or supplier onboarding. The development of these policies is a stated priority and is being actively progressed.

Where they exist, this policy should be read in conjunction with:

• Recruitment and Selection Policy
• Grievance Policy
• Equality, Diversity and Inclusion Policy

The following policies are identified as priority items for development:

• Whistleblowing Policy
• Anti-Bribery and Corruption Policy
• Supplier Code of Conduct / Supplier Onboarding Policy
• ESG / Sustainability Policy

Until such time as formal policies are adopted, the principles set out in this document and in Beauhurst’s employment contracts and supplier agreements continue to apply.