Group Modern Slavery Act Statement

We are committed to improving our practices to combat slavery and human trafficking. This statement is made in accordance with the Modern Slavery Act 2015, and sets out the steps taken by Privilege Group for the year ending December 2020. All information provided under this statement is produced in accordance with the 2022 financial year end.

ORGANISATION STRUCTURE

We are a provider of funds and investments in the financial services industry. We are part of the Privilege Group (Group) and our parent companies include Privilege Holdings Limited and Privilege Holdings 2 Limited. The Group operate in the UK and EU and 76 employees across two subsidiary companies, Privilege Finance Services Limited and Eco Verde Energy Limited.

OUR SUPPLY CHAIN

Our supply chains include, but is not limited to:

1. 1. AD plant feedstock suppliers
2. 2. Funding entities
3. 3. Cleaning companies
4. 4. Hotels and other accommodation providers
5. 5. Clothing manufacturers; and
6. 6. Delivery/courier service providers

ORGANISATION STRUCTURE

We are committed to ensuring that there is no modern slavery or human trafficking in accordance with our obligations under the MSA 2015 and corresponding legislation, where  applicable, in our supply chains and in any part of our business. In particular, we are committed to acting ethically and with absolute integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensue that slavery and human trafficking is not taking place anywhere in our supply chains and other business. We expect the same standards of compliance from our contractors, suppliers, and other business partners.

DUE DILIGENCE: FINANCIAL YEAR 2022

As part of our initiative to identify and mitigate risk we have in place systems to:

1. 1. Identify and assess risk factors in our external business relationships including our supply chains and contractors.
2. 2. Mitigate the risk of slavery and human trafficking occurring in our external business relationships including our supply chains and contractors.
3. 3. Monitor potential risk factors in our external business relationships including our supply chains and contractors; and
4. 4. Protect whistleblowing.

We have a zero tolerance approach to slavery and human trafficking. To ensure our supply chains and other business relationships comply with our ethics, we have in place a rigorous compliance programme that consists of:

• A Modern Slavery Policy which is implemented across all established supply chains.
• Standard Contractual Documents that are periodically reviewed and updated.
• Implementation of new contractual provisions requiring supply chains to comply with the MSA 2015, this is inclusive of, but not limited to, ensuring all board members, including any board member of a contracting Special Purpose Vehicle, is aware of their obligations under the MSA 2015 in accordance with our Modern Slavery Policy.

TRAINING

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff and we also require our business partners to provide training to their staff and suppliers and providers.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING: FINANCIAL YEAR ENDING 2022

All policies, procedures and documentation are, to date, reviewed and new business partners under our supply chain are thoroughly identified to ensure full compliance with the MSA 2015.

RISK ASSESSMENT

Risk assessments are conducted in accordance with our internal code of conduct that is put forth to all entities under our supply chain. We monitor compliance with this code and suggest that any such entity under our supply chain incorporate our code of conduct where necessary. In the absence of entities under our supply chain incorporating our code of conduct, we ensure that they are contractually required to comply with all relevant laws and regulations.

FURTHER STEPS

Following a review of the effectiveness of the steps we have taken for 2022 to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:

1. 1. Review and monitor compliance across all entities contained under our supply chain.
2. 2. Ensure all new entities under our supply chain have in place acceptable modern slavery standards and make available our code of conduct.
3. 3. Conducting periodic risk assessments with reference to our extended supply chain.

APPROVAL

This statement is made pursuant to section 54(1) of the MSA 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending December 2022. It was approved and signed by the board on 01 March 2023.