Modern Slavery Statement

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and sets out the steps we have taken to ensure that our business as well as our supply chains are free from slavery and human trafficking during the financial year ending December 2025.

In May 2025, the UK Government published the “Transparency in Supply Chains (TISC) Statutory Guidance”, which sets clearer expectations for organisations preparing Modern Slavery Statements, including recommended disclosures and levels of detail. Microlise acknowledges this updated guidance and is committed to ensuring our reporting aligns with it. We will use the updated guidance to inform enhancements to our approach and reporting.

Microlise Group Plc (“Microlise”) is committed to preventing modern slavery and human trafficking occurring in any of its corporate activities, as well as seeking to ensure that our supply chains are also free from such practices in the UK, Europe, and beyond.

Microlise is a provider of hardware, software and professional services to vehicle manufacturers, as well as organisations operating road transport fleets or with a requirement to track mobile assets.

We employ approximately 800 people worldwide and operate in the UK, Ireland, Europe, India, Australia and New Zealand through our customers’ use of our products and services in their vehicle fleets. We have subsidiary companies in the UK, France, India, and Australia.

We have a total annual turnover of £84 million.

Nature of our supply chains

Our key supply chains involve electrical hardware manufacturing, sub assembly in the UK, and raw material components from the Far East. We are moving towards procuring both contract manufacturing of Microlise designs as well as electrical products and components manufactured in the Far East. Other general business use suppliers include publishing and printing services , IT hardware and software services, data centres, conference and venue suppliers, training providers, consultants, legal consultants, marketing and PR services, installation and service engineers, etc.

Governance structure and responsibility

Responsibility for this Modern Slavery Statement rests with Microlise’s Board of Directors. All employees are responsible for following Microlise Policies and for reporting breaches thereof, including of this Modern Slavery Statement. New suppliers are subject to a documented approval process including review by Procurement, Legal, and a director where appropriate.

Microlise maintains a set of established policies and procedures which govern its operations and interactions with customers and suppliers. These include:

• Whistleblowing Policy:Microlise encourages employees and workers to report any suspected wrongdoing, including unethical behaviour, legal breaches, or risks to people or the business. The policy details confidential reporting routes and investigation procedures to ensure concerns are properly addressed and acted upon, with protection from retaliation.
• Anti‑Harassment & Bullying Policy:Microlise is committed to providing a safe and respectful working environment free from harassment, bullying or intimidation. The policy explains what constitutes unacceptable conduct, how employees can raise concerns, and the formal investigation and protection measures in place to safeguard those affected.
• Recruitment & Selection Policy:Microlise’s recruitment processes ensure fair, transparent, and lawful recruitment practices. The policy dictates compliance with employment legislation and transparent procedures for advertising, interviewing, and onboarding employees.

Microlise also maintains a detailed Supplier Management Policy to govern its supply chain management.

Communication and implementation

Policies are available at all times for employees to access on Microlise’s intranet portal. Employees, managers and the executive committee have a responsibility to ensure that policies are followed by all employees, and to flag breaches. Where policies are not adhered to, investigations take place to determine the next course of action.

Policies are reviewed and updated annually wherever possible and appropriate.

As part of our Supplier Management Policy, we have reviewed the risks that our supply chains can present and will seek to continually review the operations of existing suppliers in relation to the risk of modern slavery and human trafficking. We do this by asking our new suppliers to complete a supplier questionnaire detailing our corporate social responsibility requirements, to which all suppliers must conform. This is then reviewed on a bi-annual basis and the risk recorded. This review records the location, policies, certifications, and standards held by suppliers to drive a risk-based scoring matrix to define the strategic key suppliers and the suppliers requiring further monitoring. The compliance elements submitted by suppliers are then monitored and kept up to date regularly to ensure continual compliance.

On the risk register, suppliers are classified based on location, with higher risk levels assigned to regions such as the Middle East. This is in line with statistical data showing the prevalence of modern slavery by geographic region, such as the International Labour Organization’s “Global Estimates of Modern Slavery”. Suppliers are also classified based on the category of products and services provided, with higher risk levels assigned to physical manufacturing compared to virtual services.

Suppliers with higher risk levels are flagged for greater oversight and management. For example in 2025, we conducted in-person visits to various direct suppliers in China.

We expect our suppliers and contractors to demonstrate a zero-tolerance approach to exploitation. To this end, we require that our suppliers, and their subcontractors, comply with the Act, and accept and subscribe to the principles outlined in this Modern Slavery Statement. Moreover, Microlise reserves the right to terminate supplier contract in the instance of any breach of the obligations connected to Anti-Slavery legislation.

As part of our procurement process, we will only engage with suppliers and contractors who confirm their compliance with the Act. We consider our exposure to modern slavery to be limited. We monitor and manage the risk of our supply chain by pre-appraising new vendors and continually monitoring existing vendors. We will seek specific assurances from those suppliers carrying the highest exposure to risk. Microlise also conducts site visits, including Procurement staff visiting suppliers in higher-risk geographical areas such as the Middle East and China to review risk.

We are committed to implementing and enforcing effective procedures and controls to minimise the risk of human trafficking and other modern slavery practices infiltrating our business operations or supply chains, and to acting ethically and with integrity in all our business activities and relationships. We expect our employees to fully comply with the Modern Slavery Act 2015 and our associated procedures.

Improvement

Since the last update of the Modern Slavery Statement, Microlise has strengthened its supplier review and monitoring process, as well as continuous improvements to the Supplier Management Policy. It has also revised and expanded several internal Policies.

Non-compliance

Any non-compliance with policies and procedures would result in facing disciplinary procedures in accordance with Microlise’s Disciplinary Policy & Procedure, which can result in actions such as investigation, suspension, disciplinary hearing, sanctions, written warnings, and dismissal.

No incidents of non-compliance with applicable laws and policies have currently been reported.

We provide training to key staff to ensure that they understand the risks of modern slavery and human trafficking infiltrating our business or supply chains and effectively operate our policies and procedures aimed at mitigating this risk.

Training is delivered to staff in a multitude of ways depending on the subject, including online third-party training tools as well as in-house training. All employees are required to complete a set of mandatory training courses, including refresher training at varying frequencies. Specific training on modern slavery is delivered through an online platform.

During the year 2026, we plan to:

• Continue to monitor the supply chain and supplier risk bi-annually, recording the risk and undertaking the supplier business reviews required, based on the risk scoring;
• Continually monitor supplier compliance and ensure this is up to date and accurate;
• Visit and audit of key suppliers to ensure their compliance;
• Enhance the level of disclosure and provide clearer information in our Modern Slavery Statement relating to the following areas, in accordance with updated guidance from the UK Government:
  • Organisational structure, including supply chains
  • Organisational policies
  • Assessing and managing risk
  • Due diligence in relation to modern slavery
  • Training
  • Monitoring and evaluation
• Review our internal processes to ensure that our annual statement continues to meet statutory requirements.

This statement was approved by the Board on the 29^th of April 2026.

This statement was approved and signed by:

Nadeem Raza
Chief Executive Officer for Microlise
Date of signature: 26-March-2026