Modern Slavery and Human Trafficking Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and sets out the steps taken by EWL Living (EWL) during the financial year ended 31 October 2024 to ensure modern slavery and human trafficking, collectively referred to as “modern slavery” in this statement, is not taking place in any part of our business or any of our supply chains and the effectiveness of such steps in respect this regard.

The Act applies to EWL Living Development Company Limited, EWL Living Holdings Limited, and its subsidiaries and associated companies (together known as “EWL Living,” “we” “our” and “us”).

At EWL Living, we recognise that slavery and human trafficking are significant human rights issues and are committed to taking appropriate and proportionate steps to mitigate the risk of these occurring within our business and our supply chain. Our approach in tackling modern slavery builds upon our core vision and values, which focus strongly on people and relationships, and we are committed to combating modern slavery and ensuring transparency throughout our supply chain.

Our business and Supply Chain

EWL Living is a London-based property developer operating within the UK. The key areas of our business operations that could be affected by modern slavery and human trafficking are directly hired employees, agency workers working on our behalf, sub-contractor operatives working on our sites, and the workforce of our supply chain, who supply services and materials to our business.

Our Policies and Due Diligence Processes

Employees:

• We verify that all employees (both interim and permanent) have the right to work in the UK upon commencement of their employment at EWL Living.
• We make all employees aware of their working hours, leave and absence entitlements and other employment benefits via employment contracts, a thorough induction, and our Employee Handbook.

Agency workers:

• We aim to only engage agency workers through approved and vetted suppliers.
• We require all approved suppliers to ensure their agency workers have the right to work in the UK and to have procedures in place to minimise the risk of recruiting forced or compulsory labour.

Contractors and Sub-contractors:

• We require, by contract, our contractors and sub-contractors to have appropriate systems and processes in place to ensure compliance with all UK employment legislation, and they must comply with the EWL Living Modern Slavery Policy and the Modern Slavery Act, as well as confirm that their employees have the right to work in the UK.
• During our selection process, we consider potential contractors’ or sub-contractors’ approaches to employee rights and any breaches of human rights-related legislation.
• We ask all site operatives to provide evidence of their CSCS cards.
• We require all contractors and sub-contractors that purchase materials for use on our sites to consider the risk of modern slavery in their supply chain.

Suppliers:

• We work with our supply chain partners, and where we procure, the majority of our directly sourced materials are from UK-based organisations that are required to comply with UK laws, including the Modern Slavery Act. Where materials are directly sourced from outside of the UK, we consider the risk of slavery and human trafficking as part of our selection process. Our supply chain process will closely scrutinise our potential suppliers’ environmental, health & safety, equal opportunities, quality assurance, data protection, modern slavery & human trafficking, and anti-bribery and corruption policies and compliance record.

Whistleblowing:

• Our policies and procedures allow any employee or third party to confidentially raise any concerns.

Training

To ensure that the risks of modern slavery and human trafficking facing our business are understood within our organisation, we require all employees to undertake mandatory modern slavery e-learning modules each year. Training modules cover:

• how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within our organisation; and
• what steps our organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chains.

We will continue to review our in-house training programme to ensure that sufficient training is delivered to all staff on a mandatory basis and to reinforce this important message.

This statement will be reviewed and updated annually. This document has been approved by the Board of Directors of both EWL Living Development Company Limited and EWL Living Holdings Limited in June 2025.

Martin Hill, General Counsel and Robin Goodlet, Managing Director

Date: 2 June 2025