DJH Holding Group Limited and its subsidiaries

Our Commitment

DJH Holding Group Limited and its subsidiaries (“DJH”, “we” or “us”) are committed to conducting business ethically and to protecting human rights across every part of our operations. This statement sets out the steps we have taken during the financial year ending March 2026 to prevent modern slavery and human trafficking in our business and supply chains, and reflects our ongoing commitment to:

• Eliminating slavery and human trafficking from our supply chains and business operations.
• Supporting ethical business practices and responsible sourcing.
• Creating transparent, accountable processes that protect vulnerable individuals.
• Engaging meaningfully with suppliers and partners to drive positive change.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps DJH has taken during the above period. It has been approved by the Board of Directors of DJH Holding Group Limited.

Understanding Modern Slavery

Modern slavery is an international crime and a serious violation of human rights, affecting millions of people worldwide regardless of age, gender or ethnicity. Vulnerable individuals, both overseas and across the UK, continue to be coerced into working illegally across many sectors, including agriculture, construction, hospitality, retail and manufacturing.

Global Context: Developments Over the Last 12 Months

Global and domestic conditions affecting modern slavery risk have shifted over the past year. We have taken the following developments into account in reviewing our own approach:

• Rising UK referrals – the UK’s National Referral Mechanism recorded its highest ever number of referrals in 2025, a 22% increase on the previous year, according to the Independent Anti-Slavery Commissioner.
• A shift in who is affected – the Commissioner’s May 2026 report, Anticipating Exploitation: A Futures Analysis, found that UK nationals are now the largest single group of victims, with rising living costs, debt and insecure work identified as key drivers of exploitation closer to home, alongside conflict, unsafe migration routes and growing digital and AI-enabled coercion.
• Wider economic pressure on workers – the International Labour Organization has highlighted that conflict-driven disruption to energy, trade and supply chains is adding to existing labour market fragilities, with low-income households, informal and migrant workers, and small enterprises facing the greatest exposure to forced labour and other decent work deficits.

We have reflected on what these developments mean for our own risk assessment, in particular the increased focus needed on lower-wage, high-turnover roles within our supply chain, such as cleaning, catering, recruitment and facilities services, and the case for embedding stronger controls, such as our new purchase order system described below, ahead of any further tightening of the regulatory or reputational landscape.

Our Organisation and Supply Chains

DJH is a private company limited by shares, incorporated in England and Wales. We are a UK-based accountancy and business advisory group, recognised as a Top 30 firm, offering audit, tax, accounting, payroll and corporate finance services. We operate from offices across the UK and in Dublin, Ireland, and primarily serve clients in these locations.

Our supply chain is predominantly UK-based, spanning support services, IT, office supplies, facilities management, recruitment and other professional services. The majority of our external suppliers operate in sectors we consider to be lower risk for modern slavery.

Our Ethical Framework and Policies

Zero-Tolerance Approach

We take a zero-tolerance approach to any violation of UK anti-human trafficking and anti-modern slavery legislation.

Our Values in Action

Our values guide every aspect of how we do business, setting clear expectations for ethical behaviour across all our dealings with colleagues, clients and suppliers. We foster an open, transparent and trusted business environment through:

• Comprehensive Whistleblowing Framework – clear channels for raising concerns internally, supported by anonymous reporting.
• Ethics Excellence – an ethics policy and annual ethics training aligned with our code of ethics under the ICAEW.
• Anti-Bribery Commitment – robust policies, frameworks and risk assessments.
• External Complaint Management – structured processes for handling concerns raised by external stakeholders.
• Employment Excellence – policies that promote fair and inclusive workplace practices.
• Responsible Recruitment – rigorous processes to ensure compliance with employment law.
• Fair Compensation – market-aligned pay and reward, reviewed annually.
• Wellbeing Leadership – strategies and initiatives supporting our people’s physical, mental and lifestyle wellbeing.
• Client Due Diligence – enhanced client take-on processes and a framework for engagements in higher-risk sectors.

Our Due Diligence and Risk Management

Risk Assessment Strategy

Professional services are generally considered a lower-risk sector for modern slavery. Nonetheless, we proactively assess potential vulnerabilities among outsourced providers, recruitment agencies, and cleaning, catering and IT suppliers, through regular reviews and adaptive processes.

Comprehensive Due Diligence Approach

• Supplier Excellence – we review our onboarding processes against our Supplier Due Diligence requirements and carry out enhanced due diligence for higher-risk suppliers where appropriate.
• Internal Verification – we run checks on new employees and contractors, including verification of identity and right to work.
• Acquisition Due Diligence – acquisitions undergo comprehensive due diligence covering anti-bribery, whistleblowing, ethics, anti-money laundering and related matters.
• Acquisition Integration – a full integration plan on all new acquisitions is implemented with structured adoption of DJH policies and governance controls.

Strengthening Our Controls: A New Purchase Order System

We are currently implementing a new purchase order (PO) system across the group, with roll-out expected to complete in early 2027. This is a direct enhancement to the due diligence and risk management processes described above. Once fully embedded, we expect it to deliver:

• Verification before spending
• Full visibility of spend
• Stronger approval controls
• A clear audit trail
• Reduced off contract spend

We will report on the impact of the new system, including any findings from supplier verification, in future statements.

Measuring Our Impact

We track our effectiveness through the following key performance indicators:

• Ethics complaint logging and resolution tracking.
• Audit findings evidencing compliance with our policies and procedures.
• Completion of annual ethics training by all colleagues.
• Modern slavery training completed as part of every new starter’s induction.
• Ongoing monitoring of policy implementation.
• Supplier verification and spend data captured through our new purchase order system.

Our Training and Awareness

We provide regular, targeted training to build awareness of modern slavery risks, with particular focus on colleagues working in procurement and supply chain management. This training helps our people identify, report and address potential risks effectively.

Our Future Objectives

Looking ahead, we will:

• Continue to enhance our due diligence processes and supplier engagement.
• Complete the roll-out of our new purchase order system across the group.
• Expand modern slavery awareness training across all business functions.
• Strengthen partnerships with suppliers to drive ethical compliance.
• Continue to improve our risk assessment and response processes.

Our Commitment to Continuous Improvement

By embedding ethical excellence at the core of our business, DJH is committed to driving positive change in the fight against modern slavery and human trafficking. We take full responsibility for this statement and will review and update it regularly in line with the Act.

This statement relates to all businesses operating as part of the DJH Group across the UK and the Republic of Ireland and covers our obligations under the Modern Slavery Act 2015 and the Criminal Law (Human Trafficking) Act 2008, as amended by the Criminal Law (Human Trafficking) (Amendment) Act 2013.

For more information about our modern slavery initiatives, please contact [email protected].

Approval

This statement was approved by the Board of Directors of DJH Holding Group Limited on 30^th September 2026 and is signed on their behalf by:

Scott Heath

CEO

30/09/2026

Updated 30 September 2026