Upholding
Excellence and Integrity

Introduction from Nick Petheram, the Chief Executive Officer

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 in order to exploit them for personal or commercial gain. Victims of modern slavery and human trafficking can be any age, gender, nationality, and ethnicity. Nomia Group Limited, including its affiliates and subsidiaries (“Nomia”) has a zero-tolerance approach to modern slavery and human trafficking across all areas of our organisation, as well as within our supply chains.

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

This statement assesses our risk, outlines our efforts and sets commitments for the coming year.

Section 1. Organisational structure, operations and supply chains

Nomia Group Limited was incorporated on 5th February 2016 and has subsidiaries operating across the world.

Nomia uses next generation technology integrated with generative Al and cognitive search solutions to streamline and manage the non- strategic procurement processes. With a global team, we work closely with our customers to provide a comprehensive sourcing, supplier management and contract optimisation platform. This enables our customers to focus on their strategic spend. Our aim goes far beyond cost reduction. We seek to provide our customers with a next generation digital platform to improve compliance, promote transparency, source, and manage to sustainability and ESG preferences.

Nomia is head-quartered in the UK and has subsidiaries across the globe. As of the date of this statement, Nomia employs 127 full and part time workers globally.

We are trusted by many global MNCs, Telecommunication and government and public sector organisations.

We expect all of our suppliers to operate in a responsible, ethical, open and transparent way and in compliance with all applicable laws and regulations. Our global teams work closely with suppliers to communicate our standards and help them to build their capacity to provide working environments that are safe, respectful of human rights, and free of modern slavery.

Section 2. Policies and Governance

Our Anti‑Slavery and Human Trafficking Policy demonstrates our commitment to operating ethically and with integrity across all business relationships. We maintain effective systems to prevent slavery and human trafficking within our operations.

Although, we are generally assessed as being at low risk of modern slavery, we have implemented the following policies, whistleblowing protection and antibribery and corruption.

We expect the same high standards from all our contractors, suppliers, and other business partners. Our contracting processes include explicit prohibitions against the use of forced, compulsory, or trafficked labour, or any form of slavery or servitude. All suppliers are also required to comply with our Supplier Charter.

Section 3. Risk Assessment and Due diligence

Based on the nature of our business, we consider the risks of modern slavery and human trafficking to be low in our direct business operations.

Nomia’s supply chain consists of technology service providers, cloud infrastructure providers, professional services firms, recruitment agencies, and corporate service vendors. While the nature of services provided across the supply chain varies, all suppliers are subject to a due diligence process prior to onboarding. This process includes appropriate checks and screenings, as well as a requirement for suppliers to agree to Nomia’s Supplier Charter.

The majority of Nomia’s suppliers operate in the UK and other jurisdictions generally considered to be low risk for modern slavery. However, Nomia also engages suppliers to service customers based in regions that present heightened risks of modern slavery and human trafficking. .We are aware that inherent and potential risks of modern slavery and human trafficking could be present in the following principal areas:

• Supply chains

• Recruitment through agencies

• Forms of excessive or unpaid working hours, lack of rest days

• Personal identification or passport retention

• Lack of adequate health and safety protection

• Discrimination

We recognise that we have a role to play in the global effort to eliminate modern slavery and human trafficking.

Suppliers go through an onboarding process in which they are asked to comply with a minimum set of requirements in order to be included in our supplier database. This includes financial and compliance due diligence and acceptance of Nomia’s Supplier Charter.

In addition, before we trade with any supplier, we invite them to our automated Supplier Onboarding and Management platform which allows us to conduct thorough checks. This includes a risk-based questionnaire/screening tool to assess risks such as lack of insurance, relevant compliance certificates, security policies and includes assessing modern slavery risks. Suppliers are asked to update the questionnaire and supporting evidence on an annual basis.

No instances of modern slavery were identified in Nomia’s operations and supply chain for the period of this report. Should Nomia discover that a supplier is not acting in compliance with modern slavery legislation, we will take all steps necessary to remove such offending supplier from our supply chain.  Nomia expects full transparency from our suppliers around any incidents of modern slavery that may occur, or that they have been involved with.

There is a range of support available when a person becomes aware that someone is at risk of or affected by modern slavery or human trafficking practices, regardless of if this occurs within Nomia’s supply chain and operations or in the broader community. Employees are encouraged to refer to our Whistleblowing Policy which sets out how to appropriately respond to and report suspected cases.

During the period of this report, no whistleblowing complaints were received.

Section 4. Training and awareness raising

Increasing the skills and capability of our people is fundamental to our ability to conduct effective modern slavery due diligence on our supply chains.

The risk our business faces from modern slavery forms part of the induction process for all individuals that work for us. All employees are required to complete e-learning training on Modern Slavery upon induction and to refresh this training every three years.

All employees are required to familiarise themselves with our Anti-Slavery and Human Trafficking Policy. All employees complete mandatory modern slavery awareness training. Employees in procurement and supplier management roles receive additional guidance tailored to their higher exposure to identifying modern slavery risks.

Our zero-tolerance approach to modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate on an on-going basis.

Section 5. Key performance indicators to measure effectiveness of steps being taken

As well as a specific Anti-Slavery and Human Trafficking Policy, other policies and guidance support Nomia’s staff and supply chain to identify and proactively defend against modern slavery.

Section 6. Measuring effectiveness of steps being taken and KPIs

Our Supplier Charter requires our suppliers to treat people with dignity and respect. All suppliers commit to:

• comply with our Anti-Slavery and Human Trafficking Policy;

• not engage in any form of human trafficking, procure commercial sex acts or use forced labour;

• ensure that workers have freedom of movement and are free to leave their employment after reasonable notice: and

• return immediately any workers’ government-issued identification, passports or work permits once they have confirmed workers’ identities or working rights (to the extent that is required).

All suppliers commit not to:

• use misleading or fraudulent recruiting practices,

• use recruiters that do not comply with local labour laws in the country where the recruiting takes place,

• expect workers to pay for a job,

• provide housing that does not meet the standards of the country where work is performed, or

• fail to provide an employment contract or recruitment agreement if required to do so by law.

In addition, we may require suppliers to demonstrate that they have relevant policies and procedures in place.

Nomia currently has no confirmed cases of modern slavery identified within our operations or supply chain, however, it seeks to continuously improve its own purchasing practices. We understand that we can have a profound impact on the conditions of workers in supply chains through our own purchasing practices. Aggressive pricing, short lead times and late payments are just a few examples of purchasing practices that can unintentionally cause modern slavery risks.

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 Nomia and its relevant subsidiaries and affiliates on 23 January 2026.

Nick Petheram

CEO