Ģ����Ƶ

Pursuant to the United Kingdom’s Modern Slavery Act of 2015, §54(1) for the financial year ending in 2024. It sets out the steps we have undertaken, and are continuing to take, to ensure modern slavery & human trafficking are not taking place within our business or supply chain.

Our Company

Transaction Network Services (UK) Limited (“Ģ����Ƶ”) are part of a global organization who, no matter where we do business, is committed to conducting all business lawfully, with stewardship and integrity. This commitment extends through our business and supply chain and includes, among other things, an expectation that our suppliers do not use modern slavery, in any of its forms, including human trafficking, in providing product or services to Ģ����Ƶ. Our supply chains who demonstrate our shared commitment are a key part of our continued success. Ģ����Ƶ’ compliance and ethics expectations are set out in our Code of Conduct. Due to the elevated level of sophistication required in the services Ģ����Ƶ provides, there is low probability that any form of modern slavery would be utilized in our industry.

Due Diligence

At Ģ����Ƶ, we continue to improve our due diligence measures to ensure we are engaging partners who are committed to doing business the right way and have not participated in unlawful conduct, including modern slavery & human trafficking.

Our Values & the Koch Stewardship Framework

As part of the Koch Group of companies, our management framework, Principle Based Management™, is based on proven principles of human progress and a deep appreciation for the dignity of every individual. Our focus on individuals and bottom-up solutions is evident in our Stewardship Framework and drives our approach to Environmental, Social, and Corporate Governance (“ESG”).

“At Koch, stewardship encompasses the responsible management of our actions and the resources entrusted to our care in a manner that respects the rights of others. By “rights” we mean everyone’s right to their own life and property, and equal treatment under the
������.”

Our commitment to and expectations for ensuring our business and supply chain is maintained in a lawful and socially responsible way includes, among other things, that neither modern slavery nor human trafficking is taking place in any component of our business. These expectations are set out in our values to be honest, fair, and trustworthy in all our activities and are expected to:

• Comply with the applicable laws and regulations governing our business conduct worldwide;
• Avoid all conflicts of interest between work and personal affairs;
• Foster an atmosphere in which fair employment practices extend to every member of the diverse Ģ����Ƶ community; and
• Deal fairly with our customers and maintain confidentiality.

The expectation to adhere to our values not only applies internally but extends to our external supply chains as well.

Code of Conduct – Our Policies Regarding Modern Slavery & Human Trafficking

Ģ����Ƶ is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Ģ����Ƶ will not tolerate any such activities within our own operations or within our supply chain. As part of our initiative to identify and mitigate risk and ensure compliance with applicable laws, Ģ����Ƶ will continue to maintain relevant business processes and systems to:

• identify and assess potential risk areas in our supply chains;
• mitigate the risk of slavery and human trafficking occurring in our supply chains;
• monitor potential risk areas in our supply chains and undertake necessary due diligence checks; and
• protect whistle blowers.

Employee Training & Guidance

Although Ģ����Ƶ does not have a comprehensive, mandatory training program focusing on modern slavery and human trafficking, employees receive training on the employee Code of Conduct, which address and supports a supply chain free of any type of modern slavery or human trafficking, as well as avenues available for reporting concerns. The training is periodically provided through a varied methodology.

Furthermore, every Ģ����Ƶ employee has the responsibility and must have the courage to ask questions and raise concerns about compliance or ethical behavior and promptly report potential or actual violations of a law, company policy or standard, or any request to violate a law, company policy or standard.

Our Supply Chains & Adherence to our Values

We expect all those in our supply chain to comply with our values, therefore non-compliance with applicable laws, regulations, and our standards regarding modern slavery and human trafficking will result in corrective action up to and including termination, depending on the circumstances. Modern slavery, in any form, has an exceptionally low probability of being utilized in Ģ����Ƶ’ supply chain, thus creating a minimal risk profile.

Ģ����Ƶ assesses and selects its suppliers with care. We maintain the expectations outlined in our Code of Conduct for lawful and respectful business practices and extend this expectation to our suppliers, who are assess under a risk-based review. If non-conformance with our standards and guidelines were to arise, depending on the circumstances, we would either require that supplier establish corrective action and report on the implementation of such plans, or we would terminate the relationship. Review of such non- conformance must be viewed on a case-by-case analysis given surrounding information.

Approval

This statement is made pursuant to §54(1) of the United Kingdom’s Modern Slavery Act of 2015 and constitutes our slavery and human trafficking statement for the financial year ending December 31, 2024. It is approved by the Governing Board and signed by a Director.

Dated: May 15, 2025