Statement on Combating Modern Slavery – SCANDIC GROUP

Introduction

Respect for human rights is a central concern of the SCANDIC GROUP. As an international brand association – represented by SCANDIC ASSETS FZCO and the SCANDIC TRUST GROUP LLC in cooperation with the Legier Beteiligungs mbH – the group offers media, finance, real estate, mobility, health and security services and is responsible for an ethical and transparent supply chain. We do not tolerate any forms of modern slavery, forced or child labor or human trafficking. This statement describes our approach to preventing such practices, identifying risks and continuously improving our processes. It is updated annually and is part of our overarching policy stack on corporate governance, data protection, supply chain diligence and human rights.

Overview library

• 1. Our approach to modern slavery
• 2. Supply chain and risk management
• 3. Expectations of business partners
• 4. Training and awareness raising
• 5. Whistleblowing and remedial processes
• 6. Assessment and ongoing improvement

1. Our approach to modern slavery

The SCANDIC GROUP is committed to respecting human rights and fair working conditions along the entire value chain. Our principles – integrity, transparency, responsibility – require that we prevent any form of forced labor, debt bondage, human trafficking or exploitative labor practices. We are guided by international agreements such as the ILO core labor standards, the British Modern Slavery Act 2015, the German Supply Chain Due Diligence Act and other relevant legal regulations. Our statement describes the measures taken and will be published on our website.

2. Supply chain and risk management

We analyze our supply chains to identify risks of modern slavery. This includes assessing geographical, sectoral and company-specific risks and classifying our suppliers according to risk profiles. We use questionnaires, audits and certificates to check compliance with labor and social standards. For particularly risky areas, we implement prevention and remedial measures, exclude contractual partners or work closely with them on improvements.

3. Expectations of business partners

Our business partners must commit to complying with our Code of Conduct guidelines. These contain minimum standards for working hours, remuneration, occupational safety, freedom of assembly and the prohibition of any forced or child labor. We expect transparency along the supply chains, the carrying out of our own risk analyzes and the immediate reporting of compliance violations. In the event of non-compliance, we reserve the right to impose sanctions up to and including termination of the business relationship.

4. Training and awareness raising

SCANDIC GROUP employees receive regular training to recognize signs of modern slavery and respond appropriately. Training covers legal frameworks, risk factors and reporting channels. We promote awareness of human rights responsibility both in purchasing and in product and project management. Training materials are continually developed and made available in multiple languages.

5. Whistleblowing and remediation processes

We operate a confidential whistleblower system through which employees, suppliers and third parties can report violations of human rights standards. Reports are treated confidentially, investigated thoroughly and result in clearly defined corrective action. Victims or those potentially affected receive support and are protected from retaliation. Our processes are based on international standards for whistleblowing and offer options for anonymous submission.

6. Assessment and ongoing improvement

The effectiveness of our measures is regularly assessed through internal audits, external assessments and feedback from the supply chain. Findings from studies, industry initiatives and stakeholder dialogues are incorporated into improving our strategy. We publish an annual report outlining progress, identified risks and planned improvements. This ensures transparency and accountability in our efforts to combat modern slavery.