Modern Slavery Act Transparency Statement 2025

Document Classification: Alchemy-wide policy (General)

Version: 1.4

Last annual review: 1 June 2025

Last Updated: 1 June 2025

Approver: Alchemy Board of Directors

Policy Statement:

Alchemy has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships. We expect the same high standards from all of our contractors, suppliers and other business partners. We expect them to adopt the same zero tolerance approach to the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.

Introduction

Alchemy Telco Solutions Limited and its subsidiaries (“Alchemy”) is a global multi-disciplinary technology company specializing in services within the circular economy. As of 31 March 2025, Alchemy employed over 280 employees in 10 countries.

Alchemy is committed to upholding human rights and ethical practices in every aspect of its business This Modern Slavery Act Transparency Statement (“Statement”) outlines the steps Alchemy has taken to to identify and mitigate the risk of modern slavery and human trafficking within its business operations and supply chain for the year ending 31 March 2025.

Alchemy acknowledges its obligations under relevant regional legislation related to modern slavery. The applicable laws include:

Policies and Processes

Alchemy is guided by the Universal Declaration of Human Rights and the International Labour Organization’s core conventions and aligns with the UN Guiding Principles on Business and Human Rights. Alchemy recognises both the responsibility of businesses to respect human rights and the role of governments in their protection.

Alchemy has implemented a suite of policies that directly support our efforts to prevent human rights abuses, including modern slavery and human trafficking. These include:

• Code of Conduct

• Anti-Bribery and Corruption Policy

• Gifts and Hospitality Policy

• Employment Screening Policy

• Employment Handbook

These policies are regularly reviewed and updated to ensure their relevance and effectiveness. Each outlines expectations for ethical conduct, risk awareness, and reporting channels for suspected breaches.

Employees

Alchemy fosters a safe, inclusive, and respectful workplace where all employees are treated with dignity and fairness. We have robust employment screening, onboarding, and workplace conduct processes to prevent exploitation and promote a culture of integrity.

All staff are required to complete mandatory Code of Conduct training annually. This includes content on identifying and reporting unethical behaviour, including modern slavery risks. Compliance is tracked, and any non-compliance is addressed immediately.

Suppliers

Alchemy works with over one thousand across multiple countries to support the delivery of labour, materials, equipment, premises, professional services, and financial services.

We expect our suppliers to uphold the same high standards as we do. These include commitments to:

• Human rights and ethical treatment of workers

• Safe and fair working conditions

• Environmental responsibility

• Supplier diversity and inclusion

Alchemy’s supplier management system incorporates risk assessments, performance reviews, and due diligence checks. Through this system, we aim to:

• Identify and assess potential risk areas

• Mitigate the risk of modern slavery and human trafficking

• Monitor supplier compliance

• Protect whistleblowers who raise concerns

When potential risks are identified, we take appropriate actions, which may include supplier engagement, remediation plans, or discontinuation of the relationship.

Training and capacity

To reinforce our ethical culture, all employees are required to complete annual online training on the Code of Conduct, which includes a dedicated module on modern slavery and human rights risks.

Continuous improvement

Alchemy is committed to continually enhancing its approach to addressing modern slavery risks. During the 2025 reporting period, we plan to:

• Collaborate with suppliers to align on human rights and modern slavery principles

• Engage in dialogue with suppliers in high-risk categories to ensure they understand and comply with their legal and ethical obligations

• Strengthen our supplier audit and risk review protocols

We aim to establish performance benchmarks and improve transparency in tracking risk mitigation across our supply chain.

Governance

This Statement was reviewed and approved by the Alchemy Board of Directors.

Each reporting entity’s Board or governing body has reviewed and approved this Statement prior to its publication, in line with relevant legislative requirements.

Gary Noone Chairperson For and on behalf of Alchemy Telco Solutions Limited May 2025