Modern Slavery Statement

Affinity (Group) Limited

This statement is made on behalf of Affinity Group (AG). AG’s group of Companies provides administrative and related services to Corporate Entities, e-Gaming, Fintech, Esports, Aviation and Yachting. AG does not operate its business through extensive supply chains and we consider that the risk of modern slavery within our business operations to be low.

Notwithstanding, AG recognises that the client structures that it manages on behalf of clients maybe vulnerable to Modern Slavery and Human Trafficking.

AG is not bound by any statutory requirement to make this Modern Slavery Statement but recognises the importance of having robust  policies and procedures in place to forestall and prevent the Company’s operations and client entities being abused by Modern Slavery.

We are committed to improving our practices to combat modern slavery in our business by taking steps, as far as we are able, to ensure that our supply chains (and the supply chains of client entities) are free from slavery and human trafficking.

This statement sets out the steps we have taken in the financial year ending 31 December 2025 to understand potential modern slavery risks within our business structure and supply chain, and as well as the steps taken to eradicate these risks.

Why is combatting modern slavery important?

Modern slavery is the illegal exploitation of people for personal gain and takes a number of forms and includes human trafficking, forced labour, servitude and slavery.

According to the International Labour Organisation

“Approximately 50 million people live in modern slavery across the world today, including 28 million who perform forced labour”

The Modern Slavery Act 2015 was introduced in the UK and came into force on 29 October 2015 and is designed to combat the crimes of slavery and human trafficking. An overview of the Modern Slavery Act can be viewed on the GOV.UK website.

In the USA the End Modern Slavery Initiative Act of 2015 was established to address the issue of modern slavery and human trafficking in the United States and globally.

More and more jurisdictions across the globe are introducing legislation to try and forestall modern slavery and bring in consequences for those that partake or permit or allow modern slavery practices within their organisation or within their global supply chains. There is now legislation across the globe tacking Modern Slavery including laws in Australia, Canada, EU, (France, Germany, Netherlands, also have their own legislation) New Zealand, Norway, Switzerland, UK and the US.

AG is not a UK company and our annual turnover is under £36 million, and we are therefore not required to abide by the Modern Slavery Act 2015 or make a modern slavery statement under section 54 of the Modern Slavery Act 2015. However, we are making this voluntary statement to show our commitment to ethical trading principles and to set out the steps we are taking to identify risks and tackle modern slavery and human trafficking in our business and in our supply chains.

Our Policies

Whilst we recognise that the risk of slavery and human trafficking in our industry is low, and that we do not have an extensive supply-chain, we do recognise that client structures may be abused by Modern Slavery and that clients may partake in activities that may utilise modern slavery. Our internal policies nonetheless help mitigate any risks in our business or supply chain. Examples of policies that we have implemented in this regard include:

a. Anti-Slavery Policy - Our policy reflects the fact that we instil the need to ensure that all of our business relationships are transparent and ethical at their core.

b. Whistleblowing policy – Our Company Handbook sets out the right of any employee who has concerns about our Company and how it works. This includes any suspicion of slavery or human trafficking. All such concerns are raised with either their line manager or directly with senior management, whereupon they are escalated directly to the company’s Board to be dealt with in the appropriate manner on an urgent basis.

c. Anti-Money Laundering – As a Group who provide trust and company services, we are required to comply with  Anti-Money Laundering Regulations and are supervised by the appropriate regulators in the jurisdictions that we work in for this purpose. We have implemented stringent compliance and identity verification checks on all companies and individuals we provide services for, helping to reduce the risk of money laundering from criminal activities.

d. Anti-Bribery – We operate a strict anti-bribery and corruption policy which is in line with the Bribery Act 2010.

e. Equal Opportunities Statement – We are committed to encouraging diversity and eliminating discrimination in both our role as an employer and as a provider of services. Our Equal Opportunities

f. Wellbeing solutions – We operate a comprehensive range of programmes designed to improve the wellbeing of our staff, including Employee Assistance (with a 24/7 mental health helpline and free counselling for staff members and their family).

Due diligence and risk assessment

As a provider of trust and company services, our suppliers are largely made up of those delivering services in our offices (such as maintenance and cleaning) and to those supporting our business (for example, telecommunication suppliers and IT maintenance).

We consider any third parties who represent us, and suppliers who provide goods and/or services to us, as an extension of our business. That is why we work collaboratively with them to ensure they act in a way that is consistent with our ethics.

We therefore have a policy of only engaging reputable firms, including those of international standing. We work to develop deep and long-lasting relationships with external parties, setting out our expectations from the very outset and keeping in regular contact through the course of the relationship.

We have also built into our client onboarding and risk rating process a requirement to assess our client entities for risk factors of Modern Slavery and the need for additional enhanced due diligence and supply chain analysis where a risk is highlighted.

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. This is in addition to a requirement that all staff familiarise themselves with our Company policies.

We continually monitor our staff’s awareness of these policies through annual reviews.

These annual reviews, wherein each staff member is subject to a series of questions relating to the Company’s policy, features a stringent pass mark. If staff members fail to attain this pass mark, appropriate follow-up action and re-training is undertaken.

Monitoring of this policy

We recognise that the nature of modern slavery is subject to continuous evolution. We will review this policy to ensure that it is operating effectively. Where concerns have been raised through this policy, we will consider how they have been handled and, if appropriate, follow up action shall be taken.

Our performance

There are no known issues of modern slavery in our business or supply chains.

Contact us

You can contact us at Compliance@affinityco.com with any comments, questions, or suggestions regarding our statement. We welcome a dialogue with all customers and any stakeholders who are interested in this very important topic.

If you are a victim or are concerned about potential victims, you can access support internationally through the links below.

www.modernslaveryhelpline.org

www.humanity-consultancy.com/modern-slavery-helpline-directory

https://home-affairs.ec.europa.eu/policies/internal-security/organised-crime/together-against-trafficking-human-beings/national-hotlines_en

Approval of this policy

This voluntary slavery and human trafficking statement is made for the financial year ending 31 December 2025 and was approved by the Directors in November 2025