Modern Slavery and Human Trafficking Statement

Masabi Group Limited Financial Year Ending: 31 December 2025

1. Introduction

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps taken by Masabi Group Limited and its group companies – Masabi Limited, Masabi LLC, Passenger Technology Group Limited and MYTRIP BY PASSENGER LIMITED (together, the “Group”) to prevent modern slavery and human trafficking in its business operations and supply chains.

The Group is committed to acting ethically and with integrity in all business dealings and to implementing and enforcing effective systems and controls to identify, prevent, and mitigate the risk of modern slavery and human trafficking in its business operations and supply chains.

2. Our Organisation

The Group is a provider of software-as-a-service (SaaS) solutions and related hardware and services, operating across multiple jurisdictions, including the United Kingdom, Europe, North America and other international markets.

Our activities include:

• development and operation of cloud-hosted software platforms;
• provision of mobile applications and APIs;
• integration with third-party systems and payment providers; and
• procurement and deployment of hardware (where applicable).

The Group operates primarily through professional and technical staff and engages a range of third-party suppliers to support its operations.

3. Our Supply Chains

The Group’s supply chains primarily consist of:

• cloud infrastructure providers (e.g. hosting and data services);
• software vendors and development partners;
• hardware manufacturers and distributors; and
• professional services providers (including consultants and contractors).

We recognise that modern slavery risks may arise particularly in:

• hardware manufacturing and electronics supply chains;
• outsourced services in higher-risk jurisdictions; and
• extended supplier tiers beyond our direct contractual relationships.

4. Policies and Governance

The Group maintains policies designed to mitigate the risk of modern slavery, including:

• Code of Conduct requiring ethical business practices and compliance with applicable laws;
• Whistleblowing Policy enabling confidential reporting of concerns; and
• Anti-Bribery and Corruption Policy, supporting broader ethical conduct.

These policies are reviewed periodically and communicated to relevant employees.

5. Due Diligence and Risk Management

The Group intends to adopt a risk-based approach to managing modern slavery risks, including:

5.1 Supplier Due Diligence

• implementation of a Supplier Code of Conduct which sets expectations regarding labour standards, including prohibition of forced labour, child labour and human trafficking;
• onboarding checks for key suppliers, where appropriate;
• contractual requirements for compliance with applicable anti-slavery laws as required; and
• risk-based assessment of suppliers depending on geography, sector and service type, as applicable.

5.2 Contractual Controls

Where appropriate, supplier agreements may include provisions requiring:

• compliance with the Modern Slavery Act 2015 and equivalent legislation;
• implementation of appropriate policies and controls; and
• audit and termination rights in the event of non-compliance.

5.3 Ongoing Monitoring

• periodic review of critical suppliers;
• escalation procedures for identified risks; and
• integration of modern slavery considerations into procurement processes.

6. Training and Awareness

The Group provides training and guidance to all employees, particularly those involved in:

• procurement;
• supplier management; and
• people operations.

This training is designed to:

• raise awareness of modern slavery risks;
• enable identification of warning signs; and
• ensure appropriate escalation of concerns.

7. Effectiveness and Key Performance Indicators

To assess the effectiveness of our approach, the Group intends to monitor:

• completion of supplier due diligence checks;
• inclusion of modern slavery clauses in key supplier contracts;
• number of reported concerns via whistleblowing channels; and
• employee training completion rates.

We are developing our metrics in line with evolving best practice.

8. Continuous Improvement

The Group is committed to continuous improvement in its approach to preventing modern slavery. Planned actions include:

• enhancing supplier risk assessment processes;
• expanding supplier engagement and compliance monitoring;
• reviewing policies against updated UK Government guidance; and
• aligning with broader ESG and human rights frameworks where appropriate.

9. Approval

This statement has been approved by the Board of Directors of Masabi Group Limited and is signed on its behalf by Brian Zanghi, Director on 23rd July 2026.