Modern Slavery and Human Trafficking Statement

1. Introduction and Commitment

This statement sets out Corpshore Solutions Corporation's actions to understand all potential modern slavery and human trafficking risks related to our business and the steps we have taken to ensure that slavery and human trafficking is not taking place within our business or our supply chains. This statement is published in accordance with our obligations as a service provider to UK-based clients subject to the UK Modern Slavery Act 2015, and reflects our broader commitment to ethical employment practices globally.

Modern slavery is a serious crime and a grave violation of fundamental human rights. It takes several forms, including slavery, servitude, forced and compulsory labour, and human trafficking. Corpshore Ghana recognises that as a BPO and outsourcing company serving global clients — particularly in the United Kingdom, Europe, North America, and the Middle East — we have both a moral and, increasingly, a legal obligation to take robust steps to prevent, detect, and address modern slavery risks.

As Ghana's leading BPO company, we employ hundreds of Ghanaian professionals and engage with supply chains spanning technology, facilities management, professional services, and telecommunications. We take seriously our responsibility to all workers in these chains and to the communities in which we operate.

Our commitment is grounded in Ghana's constitutional protections, the Labour Act 2003 (Act 651), the Human Trafficking Act 2005 (Act 694), the ILO Conventions on Forced Labour (No. 29 and No. 105) and Child Labour (Nos. 138 and 182) that Ghana has ratified, and the principles of the United Nations Guiding Principles on Business and Human Rights (UNGPs).

2. Legal Basis for This Statement

This statement is produced in accordance with Section 54 of the UK Modern Slavery Act 2015, which requires commercial organisations that supply goods or services in the United Kingdom with an annual turnover of £36 million or more — or that are part of a corporate group meeting that threshold — to publish an annual statement setting out the steps they have taken during the financial year to ensure that slavery and human trafficking are not taking place in their supply chains or in any part of their own business.

As Corpshore Ghana provides BPO, IT outsourcing, and AI outsourcing services to clients based in the United Kingdom and other jurisdictions that have adopted analogous legislation, we publish this statement voluntarily and as a matter of best practice, irrespective of whether we are technically required to do so under English law. We consider transparency on modern slavery matters to be an integral part of responsible business conduct.

This statement also reflects obligations under:

• The Ghana Human Trafficking Act 2005 (Act 694), which criminalises trafficking in persons and imposes obligations on individuals and organisations to report suspected cases.
• The Ghana Labour Act 2003 (Act 651), which prohibits forced labour, sets minimum employment standards, and provides for worker rights including freedom from discrimination and the right to organise.
• ILO Convention No. 29 (Forced Labour Convention, 1930) and its 2014 Protocol, ratified by Ghana, which require states to suppress all forms of forced or compulsory labour.
• ILO Convention No. 182 (Worst Forms of Child Labour Convention, 1999), ratified by Ghana, which prohibits the worst forms of child labour including trafficking of children and their use in hazardous work.

3. Organisation Structure

Corpshore Solutions Corporation is the group parent company of the Corpshore group of companies. The group operates through subsidiary and affiliated entities across more than eighteen countries, including the United Kingdom, the United States, the European Union, the United Arab Emirates, the Philippines, Vietnam, Colombia, and others. Our operational headquarters are in Accra, Ghana, from which our BPO and outsourcing services are primarily delivered.

The Corpshore Ghana entity is the primary service delivery entity for the group's BPO, IT outsourcing, and AI outsourcing services. Our workforce in Ghana is predominantly composed of Ghanaian nationals employed on full-time, documented employment contracts. We do not use agency labour or zero-hours contracts for our core operations. All employment relationships are directly with Corpshore Solutions Corporation or its Ghanaian subsidiaries.

Group entities share a common code of conduct, ethical employment standards, and anti-modern slavery policies. Each entity is responsible for local implementation and compliance with both group standards and applicable local law. The Ghana entity's compliance with this statement is overseen by our senior leadership team, with ultimate accountability at board level.

Our business activities are concentrated in office-based, knowledge-work environments in Accra. We do not operate in high-risk sectors such as agriculture, construction, or domestic work, which traditionally carry higher risks of forced labour and trafficking. However, we recognise that modern slavery risks exist in all sectors and geographies and we take a proactive approach to identifying and mitigating those risks.

4. Our Supply Chain

Corpshore Ghana's supply chain is principally composed of the following categories of suppliers and partners:

4.1 Technology and Software Providers

• Zoho Corporation — SaaS CRM, recruitment, and campaign software. Zoho is a global company headquartered in India, with its own modern slavery and ethical sourcing policies. We rely on Zoho's published statements and ISO certifications as evidence of their compliance.
• Hostinger — Web hosting services, headquartered in Lithuania, EU. Subject to EU labour standards and modern slavery obligations applicable in the European context.
• Cloudflare — CDN and security services, headquartered in the United States. Subject to US employment law and publishes its own sustainability and ethical conduct reports.
• Cloud infrastructure providers — Microsoft Azure, Amazon Web Services, and Google Cloud, as applicable to specific client engagements. All are major global corporations with publicly available modern slavery statements and extensive supplier codes of conduct.
• Telecommunications providers — Local Ghanaian telecommunications companies providing internet connectivity and telephony services. We select established, licensed providers regulated by the National Communications Authority of Ghana.

4.2 Facilities and Facilities Management

Our office facilities in Accra are managed through contracts with local facilities management and security companies. This supply chain category presents a moderate modern slavery risk, given the labour-intensive nature of security and cleaning services and the potential for labour exploitation in this sector. We apply specific due diligence to our facilities suppliers as described in section 6.

4.3 Professional and Advisory Services

We engage lawyers, accountants, consultants, and other professional service providers, primarily in Ghana and internationally. This supply chain category carries a relatively low modern slavery risk. We nevertheless include professional service suppliers in our broader supplier code of conduct requirements.

4.4 Equipment and Hardware

We procure computers, headsets, office furniture, and other equipment. Electronics and hardware supply chains carry known risks of forced labour and exploitative conditions, particularly in the mining of raw materials and in manufacturing. Where possible, we purchase from established, reputable brands with published modern slavery disclosures and verified supply chain standards.

5. Risk Assessment

We have assessed the modern slavery and human trafficking risks associated with our own operations and our supply chain, taking into account sector-specific risks, geographical risk factors, and the nature of our business activities.

5.1 Own Operations Risk

Our own operations in Ghana present a low risk of modern slavery, for the following reasons:

• All staff are employed on documented, written contracts of employment compliant with the Ghana Labour Act 2003.
• All staff are paid at or above the national minimum wage set by the National Tripartite Committee and the minimum wage applicable in the BPO sector.
• Our operations are office-based, skilled, and knowledge-intensive. Our workers are educated professionals who exercise meaningful choice in their employment.
• We do not operate in remote or isolated locations where workers might be more vulnerable to exploitation.
• We operate a documented recruitment process through Zoho Recruit, with multiple approval stages that prevent coercive or fraudulent recruitment.

Despite this low risk profile, we continue to monitor for signs of exploitation within our own operations and maintain open reporting channels for staff to raise concerns.

5.2 Supply Chain Risk

Our supply chain risk assessment identifies the following areas of elevated risk:

• Facilities management and security: Moderate risk due to labour-intensive nature and potential for sub-contracting without adequate oversight. We mitigate this through supplier vetting and contractual requirements.
• Hardware and equipment supply chains: Moderate risk due to globalised manufacturing and raw material extraction. We mitigate by purchasing from major, publicly accountable brands.
• Telecommunications infrastructure: Low to moderate risk; managed by selecting regulated, licensed operators.
• Professional services: Low risk; managed through standard contracting and relationship management.

6. Due Diligence Procedures

We apply the following due diligence procedures to manage modern slavery risks across our operations and supply chain:

6.1 Employment Due Diligence

• All new employees are required to provide proof of age and identity as part of our onboarding process. We do not employ anyone under the age of 18.
• All employment contracts are provided in writing, in English and, where requested, in a language the employee understands, before the employment relationship commences.
• We never charge recruitment fees to candidates. All recruitment costs are borne by Corpshore Ghana.
• We do not retain workers' identity documents. All documentation submitted for verification purposes is returned to the employee promptly.
• We conduct exit interviews to identify any concerns that staff may have been unwilling to raise during employment.
• We pay wages directly to employees' bank accounts, ensuring that wages cannot be intercepted by third parties.

6.2 Supplier Due Diligence

• All new suppliers are required to complete a supplier onboarding questionnaire that includes questions on their labour practices, employment standards, and approach to modern slavery.
• Suppliers with direct labour exposure (facilities management, security) are subject to enhanced due diligence, including requests for written employment policies, evidence of wage compliance, and references from other reputable clients.
• All supplier contracts include a standard modern slavery clause requiring compliance with applicable anti-trafficking and forced labour laws, and the right for Corpshore Ghana to terminate the contract if a supplier is found to be involved in modern slavery.
• We review our key suppliers' published modern slavery statements annually and raise any concerns with the relevant supplier.
• New high-risk suppliers are subject to on-site assessment before contracts are awarded.

7. Policies and Governance

Our approach to modern slavery is supported by the following internal policies and governance arrangements:

• Anti-Modern Slavery Policy: An internal policy setting out Corpshore Ghana's zero-tolerance position, staff responsibilities, reporting procedures, and investigation process. This policy is reviewed annually and approved by the board.
• Recruitment Policy: Sets out standards for ethical recruitment, including prohibition on recruitment fees, minimum age requirements, documentation requirements, and anti-discrimination provisions.
• Code of Conduct: Applicable to all staff and directors, covering ethical behaviour, prohibition on exploitation of workers, and obligations to report concerns.
• Supplier Code of Conduct: Incorporated by reference into all supplier contracts, setting out minimum labour standards, prohibition on forced and child labour, and compliance with applicable law.
• Whistleblower Policy: Provides protected channels for staff to report concerns about modern slavery or other ethical violations, without fear of retaliation. Reports may be made anonymously through our internal HR helpline or directly to the HR Director.
• Grievance Policy: Provides a formal process for staff to raise workplace concerns, including concerns about working conditions, wage theft, or coercive practices.

Oversight of modern slavery compliance rests with the HR Director and General Counsel, with board-level accountability. The board receives an annual report on modern slavery risk and compliance, which informs the preparation of this statement.

8. Training and Awareness

We recognise that effective action on modern slavery requires staff at all levels to understand the risks, recognise the signs of exploitation, and know how to respond. Our training approach includes the following:

• Mandatory induction training: All new employees receive training on modern slavery awareness as part of their onboarding programme. This training covers the definition of modern slavery, the warning signs that a colleague, client, or supplier may be a victim, and the steps to take if a concern is identified.
• Annual refresher training: All staff complete a refresher module annually to ensure awareness remains current and to reflect any changes in law or policy.
• Management training: Line managers and HR staff receive additional training on identifying signs of exploitation within the workforce, conducting sensitive conversations with potential victims, and the legal obligations of the organisation and the individual.
• Procurement training: Staff involved in supplier selection and management receive training on modern slavery risk in supply chains and the due diligence questions to ask during supplier onboarding.
• External resources: We signpost staff to external resources from the Ghana Police Service, the Ghana Labour Commission, the International Labour Organization (ILO), and the UK government's Modern Slavery Helpline (116 000) for use where a client-side concern is identified in the course of service delivery.

9. Key Performance Indicators

We measure our performance on modern slavery prevention and detection against the following key performance indicators, which are reported to the board annually:

Additional KPIs monitored internally include:

• Percentage of staff who have completed modern slavery awareness training in the current year (target: 100%).
• Number of modern slavery concerns raised through our whistleblower and grievance channels, and the outcome of each investigation.
• Percentage of key suppliers (defined as suppliers with annual spend above GHS 50,000) who have signed our Supplier Code of Conduct (target: 100%).
• Number of supplier contracts terminated due to modern slavery or labour standard concerns.
• Average time taken from identification of a concern to completion of investigation.

10. Reporting Mechanisms

We have established multiple channels through which staff, suppliers, clients, and members of the public may report concerns about modern slavery or worker exploitation in connection with our business or supply chain:

10.1 Internal Channels

• HR Department: Employees may report concerns directly to the HR Director or any member of the HR team, either in writing, by telephone, or in person. Reports are treated confidentially and may be made anonymously.
• Anonymous HR Helpline: An anonymous reporting channel operated independently allows staff to submit concerns without identifying themselves. Details are communicated to all staff during induction and annual training.
• Direct Escalation to Management: Any employee who witnesses or suspects modern slavery in our operations or supply chain may escalate directly to a member of senior management, bypassing normal reporting lines if necessary.

10.2 External Channels

• Ghana Labour Commission: The statutory body responsible for employment disputes and labour law enforcement in Ghana. Contact: labourcommission.gov.gh.
• Ghana Police Service — Criminal Investigations Department (CID): For reporting suspected human trafficking offences under the Human Trafficking Act 2005. Emergency: 18555 or 191.
• ILO Ghana Office: The International Labour Organization maintains a presence in Ghana and provides resources and support for addressing forced labour and trafficking concerns.
• UK Modern Slavery Helpline (for UK-facing concerns): 116 000 (freephone, 24/7) or www.modernslaveryhelpline.org.
• Corpshore Ghana email: info@corpshore.solutions — for external parties including clients and partners to report concerns.

We investigate all reports of modern slavery promptly, impartially, and confidentially. Where a concern is substantiated, we will take appropriate action, including termination of employment or supplier relationships, notification of relevant authorities, and support for any victims identified.

We have a strict non-retaliation policy: no employee will suffer any detriment for reporting a genuine concern about modern slavery, even if the concern proves unfounded upon investigation, provided the report was made in good faith.

11. Measuring Effectiveness

We recognise that publishing a statement is not sufficient by itself. We are committed to continuously improving our effectiveness in preventing and detecting modern slavery. Our approach to measuring effectiveness includes:

• Annual review of this statement by senior leadership, with board approval, to ensure it remains current and reflects actual practices.
• Annual third-party audit of our employment practices, including verification of employment contracts, wage records, working hours, and recruitment procedures. Audit findings are reviewed by the board.
• Periodic review of our supplier due diligence questionnaires to ensure they reflect current best practice and emerging risks.
• Tracking and reporting on all modern slavery concerns raised, investigations conducted, and outcomes reached. This data is reviewed by the board as part of the annual modern slavery compliance report.
• Comparison of our approach against published guidance from the UK Home Office, the Gangmasters and Labour Abuse Authority (GLAA), Stronger Together, and the ILO, to identify gaps and opportunities for improvement.
• Engagement with industry groups and peers in the BPO and outsourcing sector to share learning and best practice on modern slavery prevention.

Where our review identifies gaps or areas for improvement, we commit to developing and implementing a time-bound action plan to address them, with progress reported in the following year's statement.

12. Board Approval and Sign-Off

This Modern Slavery and Human Trafficking Statement has been reviewed and approved by the board of Corpshore Solutions Corporation for the financial year 2025. It will be reviewed and republished annually, and more frequently if material changes occur in our business, supply chains, or the regulatory environment.

This statement covers Corpshore Solutions Corporation and all subsidiary entities within the Corpshore group for which it is the ultimate parent. Individual subsidiary entities operating in jurisdictions with their own modern slavery reporting requirements may publish separate statements as required by local law.

Questions about this statement or our modern slavery practices may be directed to: info@corpshore.solutions.