MODERN SLAVERY STATEMENT

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain.

We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Organisation's structure

Trinnovo Group Ltd and its subsidiaries are a group of international providers of recruitment and labour hire services in the global Digital, AI, Business Enablement sectors. The group sits under its parent company, Trinnovo Group Limited (the “Group”). The Group has over 100 employees worldwide and operates globally.

Trinnovo’s supply chain can be divided into two: suppliers of personnel i.e., Umbrella companies and suppliers of goods and services to the Group.

Trinnovo’s Policy

Trinnovo Group is committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers and other business partners.

As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards. Scope/To Whom This Policy Applies This policy applies to everyone working for Trinnovo Group or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

Due diligence and audit of suppliers

We understand though that some parts of our business and their respective supply chains have a higher risk of Modern Slavery taking place. In particular, the suppliers who provide services to our umbrella workers.

Accepting and recognising these risks allows the Group to target its resources effectively to combat the risk of Modern Slavery where it is highest. We already have an established audit programme for our umbrella suppliers where we assess matters relating to Modern Slavery including requesting copies of the supplier’s modern slavery policies to ensure they have processes in place to mitigate risks.

Training

All new employees receive policy information relating to Modern Slavery as part of their induction programme and refresher courses are provided throughout the year on request should an employee require further information on the matter. Our Associate Director for Compliance is available to our employees to advise on Modern Slavery risks.

Assessment of effectiveness

The Board of Directors has overall responsibility to ensure compliance with our legal and ethical obligation. The Head of People and Culture has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal procedures to ensure they are effective in countering modern slavery.

In order to assess the effectiveness of the steps we are taking; we monitor the following indicators:

· Completion of training through attendance at induction of employees.

· Percentage of suppliers of personnel subjected to audit.

· Reports of possible incidents of Modern Slavery.

This statement has been approved by the CEO of Trinnovo Group Ltd and is applicable to all companies within the Group.

Ashley Lawrence, Date: 10th April 2024, Chief Executive Officer.