Modern Slavery Statement

Introduction

Bolster Group is committed to maintaining the highest ethical standards in our operations and supply chains. We recognize our responsibility to combat modern slavery and human trafficking and are dedicated to preventing these practices in every aspect of our business. This statement outlines the steps we take to ensure compliance with relevant laws, including the UK Modern Slavery Act 2015, and our ongoing commitment to uphold human rights.

Our Business and Supply Chains

Bolster Group operates globally, providing professional consultancy services across multiple sectors, including finance, compliance, legal advisory, and corporate structuring. Our supply chains include partnerships with suppliers, contractors, and service providers that support our operations in regions such as Europe, the Middle East, and Asia.

We work closely with our partners to ensure that all parties adhere to ethical labor practices and comply with anti-slavery regulations. Our operations involve sectors where there is a lower inherent risk of modern slavery; however, we remain vigilant in assessing and addressing any potential risks in our supply chains.

Our Policies

We have implemented robust policies and procedures to combat slavery and human trafficking, including:

1. Anti-Slavery Policy

Our Anti-Slavery Policy outlines our zero-tolerance approach to modern slavery and human trafficking. This policy applies to all employees, contractors, and suppliers and mandates strict adherence to ethical labor practices.

2. Code of Conduct

Our Code of Conduct sets clear expectations for ethical behavior and compliance with applicable laws. It explicitly prohibits the use of forced labor, child labor, and any form of human trafficking.

3. Supplier Code of Conduct

We require all suppliers and contractors to comply with our Supplier Code of Conduct, which includes provisions related to labor rights, fair wages, safe working conditions, and freedom from forced labor.

4. Whistleblowing Policy

We encourage employees and stakeholders to report any concerns related to unethical practices, including modern slavery, through our confidential whistleblowing channels. All reports are thoroughly investigated, and appropriate actions are taken.

Risk Assessment and Due Diligence

We conduct regular risk assessments to identify and address potential risks of slavery and human trafficking in our business and supply chains. Our due diligence process includes:

• Evaluating suppliers based on their adherence to ethical labor practices.
• Conducting audits and site visits where appropriate to ensure compliance.
• Requiring contractual agreements that include anti-slavery provisions.

We prioritize suppliers operating in industries or regions with higher risks of forced labor and take necessary steps to mitigate these risks.

Training and Awareness

We provide regular training to our employees and key stakeholders to ensure they understand the risks of modern slavery and human trafficking and their role in preventing such practices. Training topics include:

• Recognizing signs of forced labor and human trafficking.
• Understanding Bolster Group’s policies and commitments.
• Reporting concerns through appropriate channels.

Performance Monitoring

We measure the effectiveness of our anti-slavery initiatives through:

• Monitoring compliance with our Supplier Code of Conduct.
• Reviewing whistleblowing reports related to labor violations.
• Conducting regular audits and assessments of high-risk suppliers.
• Tracking progress on corrective actions implemented in response to identified risks.

Looking Ahead

Bolster Group remains committed to improving our practices to combat modern slavery and human trafficking. We will continue to:

• Strengthen our policies and procedures to address emerging risks.
• Collaborate with industry partners and stakeholders to promote ethical practices.
• Increase transparency and accountability in our supply chains.

Approval and Compliance

This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and constitutes Bolster Group’s anti-slavery and human trafficking statement for the financial year ending 2024. It has been approved by the Board of Directors.

‍Bolster Group

‍‍Date: 23 January 2024