Modern slavery is a crime and a violation of fundamental human rights. It takes many forms, including slavery, servitude, forced and compulsory labour and human trafficking, all of which involve the exploitation of individuals for personal or commercial gain. Victims of modern slavery can be of any age, gender, nationality or background. Bell Integration has a zero-tolerance approach to modern slavery and human trafficking within both our operations and our supply chain.

We are committed to ensuring transparency in our business and to taking meaningful steps to address modern slavery risks in line with the Modern Slavery Act 2015 and the UK government’s updated statutory guidance published in March 2025. Responsibility for our approach to modern slavery sits within our governance framework, with oversight from senior leadership. Our policies, risk management processes and decision-making are informed by our commitment to responsible business conduct and respect for human rights. We expect the same high standards from our contractors, suppliers and business partners. Our supplier contracts prohibit the use of forced, compulsory or trafficked labour. We also require our suppliers to hold their own suppliers to the same standards.

This statement covers the financial year 1 April 2025 to 31 March 2026 (“reporting period”) and explains the actions Bell Integration has taken, the progress made, the challenges encountered, and the commitments we are setting for the future.

Organisational Structure, Operations and Supply Chain

Founded in 1995, Bell Integration is headquartered in the United Kingdom and has subsidiaries across the globe. For over 30 years, we have delivered IT hardware, technology consultancy and managed services that enable organisations to transform their IT capabilities, improve productivity and enhance operational efficiency. As of 31 March 2026, Bell Integration employed 966 people worldwide across a mix of full-time and part-time roles. We support leading organisations across the financial services, telecommunications, government and public sectors, helping them maintain IT services and infrastructure that are scalable, resilient and secure.

Our supply chain is global and diverse, with more than 800 suppliers across more than twenty countries. The majority are based in Europe, alongside the Middle East, Asia and North America. These suppliers support the delivery of goods, including IT hardware, as well as services such as recruitment agency labour, subcontracting, logistics, cleaning and catering.

We expect our suppliers, contractors and business partners to operate ethically, transparently and lawfully, and to uphold standards consistent with our values and responsible business practices. Suppliers are required to comply with applicable laws relating to modern slavery, forced labour, child labour and human trafficking. We also encourage suppliers to maintain appropriate policies, due diligence processes and grievance mechanisms within their own operations and supply chains. Where appropriate, these expectations are incorporated into supplier onboarding, contractual requirements and ongoing supplier engagement.

Commitment to the United Nations (UN) Global Compact

During the reporting period, Bell Integration became a participant of the UN Global Compact which provides a globally recognised framework for organisations to embed responsible business principles into their strategies, policies and operations. The UN Global Compact includes ten principles, focussing on four key areas: human rights, labour, the environment and anti-corruption, encouraging businesses to act responsibly and address their impacts on people and society. In relation to modern slavery, these principles reinforce the importance of respecting internationally recognised human rights, avoiding complicity in human rights abuses, eliminating all forms of forced and compulsory labour, supporting the effective abolition of child labour and promoting ethical business practices.

As a participant of the UN Global Compact, we use its ten principles as a framework to support our approach to responsible business conduct and the management of human rights risks. The principles provide guidance and help inform our policies, processes and engagement with stakeholders.

We recognise that addressing modern slavery requires ongoing vigilance and collaboration. As part of our commitment to the UN Global Compact, we will continue to strengthen our due diligence processes, enhance engagement with suppliers and other stakeholders, and review our approach in light of emerging risks and best practice. We are committed to continual improvement in promoting respect for human rights across our business and value chain.

Risk Assessment and Due Diligence

We continue to assess and monitor the risk of modern slavery and human trafficking across both our own operations and our supply chains. While the risk within our direct business operations remains low, we recognise that there are potential areas of higher risk, particularly within complex hardware supply chains, labour provision through recruitment agencies, and outsourced service providers where labour is intensive.

All suppliers go through a thorough onboarding process which includes financial and compliance due diligence and communication of Bell Integration’s Supplier Charter. UK-based suppliers are onboarded via our automated Supplier Management platform, which uses a risk-based screening questionnaire to assess issues such as compliance certification, insurance, security policies and modern slavery risk. Suppliers are required to update their information and evidence annually. For suppliers outside the UK, similar checks are conducted outside of our automated system, and we require formal acceptance of our Supplier Charter, which sets clear expectations regarding ethical business conduct, respect for human rights, the prevention of modern slavery and child labour, and sustainability.

Supplier due diligence is an ongoing process rather than a one-time assessment. We continue to engage with suppliers to promote responsible business practices, monitor emerging risks and encourage continuous improvement. If any supplier fails to meet these standards, or if we find evidence of modern slavery, we will act swiftly to investigate and, if necessary, remove them from our supply chain. In FY 2025/26, no cases of modern slavery were identified. However, we recognise that risk remains, particularly beyond our tier 1 suppliers, and that ongoing vigilance is essential.

Employees and other stakeholders are encouraged to raise concerns via our Whistleblowing Policy, which ensures confidentiality and appropriate investigation of any reports. During the reporting period, no whistleblowing complaints relating to modern slavery or human trafficking were received.

Training, Awareness and Communication

We recognise that awareness and education are essential to preventing modern slavery and upholding human rights. As part of our commitment to the UN Global Compact, we continue to promote a culture of ethical business conduct and respect for internationally recognised human rights across our organisation. All new employees are introduced to modern slavery risks during induction and are required to complete our e-learning module on modern slavery. This training is refreshed every three years and is designed to help employees understand the risks of modern slavery and human trafficking, recognise potential indicators of exploitation, and understand their responsibilities for reporting concerns.

We continue to review and enhance our training programme to reflect emerging risks, evolving legislation and recognised best practice, reinforcing our commitment to continuous improvement.

We also make sure our expectations are clearly communicated to suppliers, contractors and business partners from the outset of our relationship and reinforced through ongoing engagement. Our policies, including the Anti-Slavery and Human Trafficking Policy and Supplier Charter, are made available to all relevant stakeholders.

Policies, Procedures and Guidance

Our commitment to preventing modern slavery and respecting internationally recognised human rights is supported by a framework of policies, procedures and governance processes.

Our key documents include our Supplier Code of Conduct, Anti-Slavery and Human Trafficking Policy, Supplier Charter, Whistleblowing Policy, and Procurement Policy. Our Staff Handbook sets out the standards and employment practices expected across our organisation, including our approach to recruitment, equal opportunities, dignity and respect at work, and raising concerns where inappropriate or unethical conduct is suspected. Together, these establish clear expectations for employees, suppliers, contractors and business partners regarding ethical behaviour, respect for human rights, fair working practices and compliance with applicable legislation.

These policies are supported by risk-based due diligence procedures, supplier onboarding and monitoring processes, contractual requirements, and mechanisms for reporting and investigating concerns. We review our policies periodically to ensure they remain aligned with legislative requirements, recognised best practice and our commitments under the UN Global Compact.

Our governance framework ensures accountability at the highest levels of the business. The Board reviews and approves this statement annually.

Measuring Effectiveness of Steps Being Taken and KPIs

We understand that policies alone are not enough. To assess the effectiveness of our actions we use a range of indicators, including the percentage of suppliers signed up to our Supplier Charter, the completion rates of employee training, the number of supplier assessments conducted, and any whistleblowing reports received.

In FY 2025/26:

• 98% of new suppliers accepted our Supplier Charter or provided alternative evidence of their compliance with its principles.
• No grievances or reports relating to modern slavery were received. Docusign Envelope ID: 56BBD934-F155-88C1-82DE-14A2103E15A1
• Our performance on environmental, social and governance matters was again recognised through the renewal of our EcoVadis Bronze rating in February 2026.

We continue to review our own purchasing practices, recognising that commercial pressure such as aggressive pricing or unrealistic lead times can unintentionally increase the risk of labour exploitation. We are committed to working with suppliers in ways that promote sustainable and fair practices.

Limitations and Future Commitments

We recognise that challenges remain, particularly in obtaining visibility beyond our tier 1 suppliers and in some geographies where modern slavery risk is inherently higher.

Our priorities for FY 2026/27 include:

1. Enhancing our supplier due-diligence processes by increasing the depth of our risk assessments;
2. Strengthening engagement with suppliers operating in elevated-risk sectors; and
3. Reviewing our policies, procedures and governance arrangements to ensure they remain effective and aligned with recognised best practice

We recognise that no organisation can eliminate modern slavery risks entirely from complex global supply chains. However, through ongoing assessment, responsible engagement and continuous improvement, we are committed to taking meaningful steps to identify, prevent and mitigate these risks throughout our operations and value chain.

Following a review of the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains we are committed to improving our practices to combat slavery and human trafficking.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. This statement has been approved by the board of directors of Bell Microsystems Limited and its relevant subsidiaries on 10th September 2026.

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