Modern Slavery and Human Trafficking Statement

This statement sets out the steps Briars Group Limited (“Briars”, “we”, “our”) has taken, and continues to take, to understand, prevent and mitigate the risk of modern slavery and human trafficking in our operations and supply chains.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (Transparency in Supply Chains) and covers the financial year ending [31 March 2027].

We assess our overall inherent risk as low to moderate. As a professional services firm, our own operations involve skilled office-based work with low exposure to forced labour. However, we operate across multiple jurisdictions and engage overseas suppliers and outsourced service partners, and we recognise that modern slavery — including slavery, servitude, forced or compulsory labour, and human trafficking — can occur in any sector and any country. We are committed to continuous improvement and to acting promptly where concerns are identified.

Governance and Accountability

Overall accountability for tackling modern slavery sits with the Board and Senior Leadership Team. The Compliance function leads on modern slavery policy, risk assessment and due diligence standards, supported by People/HR on recruitment and safeguarding controls, and by budget holders and contract owners who are responsible for applying proportionate due diligence to the suppliers and partners they manage and for escalating concerns.

Modern slavery forms part of our wider compliance framework, alongside our anti-money laundering, sanctions screening and know-your-client procedures. This statement is approved by the Board and signed by a director and is reviewed at least annually to ensure our controls remain proportionate to our risk profile and aligned with government guidance and good practice.

About Briars

Briars is a UK-headquartered professional services firm providing international expansion support to businesses, including payroll, human resources, accounting, tax, corporate secretarial and related compliance services across multiple jurisdictions. We act for clients ranging from start-ups entering new markets to established multinational groups.

Our Commitment to the principles of the Modern Slavery Act 2015

Briars is committed to the principles of the Modern Slavery Act 2015 and to the abolition of modern slavery and human trafficking. We have a zero-tolerance approach to modern slavery in our business and supply chains.

As an equal opportunities employer, we are committed to creating and maintaining a non-discriminatory and respectful working environment. We want all our staff to feel confident that they can raise concerns and expose wrongdoing without any risk to themselves.

Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK (or the relevant jurisdiction of employment) and to safeguard employees from abuse or coercion.

We do not knowingly enter into business with any organisation, in the UK or abroad, which supports or is found to be involved in slavery, servitude or forced or compulsory labour.

Our business and supply chain

Our supply chains are relatively limited and consist primarily of professional services, in-country service partners, IT and software providers, outsourced staffing and back-office support, and office-related goods and services.

Because we deliver services in multiple jurisdictions, some of our suppliers and partners are located overseas, including in territories where labour standards and enforcement vary. We also recognise that outsourced staffing arrangements and labour-intensive services carry a higher inherent risk than other categories of spend. Where we procure these services, or goods sourced through longer supply chains, we apply greater scrutiny proportionate to the risk.

In addition, through our client onboarding and know-your-client procedures we remain alert to indicators that a client or its ownership structure may be connected to forced labour or human trafficking, and we will decline or exit relationships where such concerns cannot be resolved.

Our policies in relation to the Modern Slavery Act 2015

The following policies, available to all staff, support our approach and set out the standards required of our people:

• Modern Slavery Policy
• Partner Code of Conduct
• Whistleblowing / Speak Up Policy
• Anti-Bribery and Corruption Policy
• Bullying and Harassment Policy
• Equal Opportunities and Diversity Policy
• Anti-Money Laundering and Sanctions Policies

Due diligence in our operations and supply chains

Our due diligence is proportionate to our size, activities and risk profile and includes:

• risk-based screening of suppliers and in-country partners at onboarding, including sanctions and adverse media checks where proportionate
• including appropriate modern slavery, ethical employment and audit clauses in supplier contracts and terms and conditions
• maintaining recruitment controls to ensure workers are legally entitled to work and are engaged on fair and lawful terms
• providing clear routes for staff to raise concerns, including through our whistleblowing arrangements
• challenging abnormally low-cost tenders or fee proposals where appropriate, to help ensure pricing does not rely on unethical labour practices
• applying our client due diligence and ongoing monitoring procedures to identify clients or beneficial owners potentially connected to forced labour or trafficking

Risk assessment and management

We assess modern slavery risk when we procure goods and services, appoint in-country partners, manage contracts, onboard clients and recruit staff. Our approach prioritises higher-risk areas — for example, outsourced staffing, labour-intensive services and suppliers located in higher-risk jurisdictions — and considers factors such as the nature of the service, the use of subcontractors, and where goods or services are sourced. This includes:

• requiring suppliers and partners to comply with applicable laws and our contractual expectations on ethical employment
• seeking assurance, where proportionate, on how suppliers prevent modern slavery in their own operations and supply chains
• using contract and relationship management to identify issues early, through performance reviews and escalation routes
• acting on concerns, including investigating, requiring corrective action, and terminating relationships for serious breaches

Embedding the principles

We will continue to embed the principles of the Modern Slavery Act 2015 through our policies, procurement, contract management, and learning and development. This includes:

• providing modern slavery awareness training and guidance for staff, with enhanced training for those involved in procurement, supplier management, client onboarding and recruitment
• reviewing our people, procurement and compliance policies so they continue to reflect modern slavery risks and prevention measures
• ensuring our contract templates and engagement terms include appropriate provisions on modern slavery and human trafficking
• maintaining a zero-tolerance approach and encouraging staff, suppliers and partners to report concerns, with clear escalation routes
• working with suppliers and in-country partners, where appropriate, to promote good practice and improve visibility of risks in our supply chains

Measuring effectiveness

We will keep our approach under review and, where proportionate, use indicators to understand its effectiveness, including completion of relevant training; evidence of modern slavery considerations in procurement and onboarding activity; and the number and nature of concerns raised and addressed through our reporting routes.

If a member of staff suspects modern slavery or human trafficking connected with our operations, clients or supply chains, they are encouraged to report it promptly through line management or our whistleblowing routes. We will take all concerns seriously, investigate appropriately, and work with relevant partners or authorities where required.

Approval

This statement was approved by the Board of Directors of Briars Group Limited, for the financial year ending 31 March 2027.

This statement will be reviewed and updated annually.

Last updated 02 July 2026.