Modern Slavery Statement

Statement for the year to 31 December 2026 · Published 8 September 2026

1. Introduction

Modern slavery, in all its forms, including forced labour, bonded labour, child labour and human trafficking, is a crime and a violation of fundamental human rights. Eppur will not tolerate it in any part of its business or supply chain.

Eppur is not currently required to publish a statement under section 54 of the UK Modern Slavery Act 2015 or equivalent legislation elsewhere. We publish this statement voluntarily, in the spirit of that Act, because we develop infrastructure in markets and sectors where the risk of labour exploitation is real, and because we expect to be held to the standard of a business many times our current size.

This is our first statement. It describes our structure, where we believe the risks lie, the commitments we have made and the steps we are taking. We will update it annually and report on progress against the measures in section 8.

2. Our business

Eppur is a global Data Centre developer. Together with our group companies, we originate, develop and finance AI Data Centre campuses and the renewable power behind them. Our pipeline stands at 5.7 GW across 12 markets on three continents, with 952 MW of anchor projects in the United Kingdom, Latvia, Greece, North Macedonia, Albania, Montenegro and Brazil. We have offices in Dublin, London, Tel Aviv, New York and São Paulo.

We are a development-stage business. Our direct workforce is small and professional, and the labour risk in our business sits overwhelmingly in the supply chains of the projects we develop rather than in our own employment.

3. Our supply chains

Delivering a Data Centre campus draws on the following categories of supplier, each with its own tiers of subcontractors and manufacturers:

• Construction and engineering: civil works, building contractors, EPC contractors, and the site labour they employ directly or through agencies.
• Electrical and mechanical equipment: transformers, switchgear, generators, uninterruptible power supplies, cooling systems and their component supply chains.
• Renewable generation and storage: solar modules, inverters, wind turbines, battery systems and the raw materials behind them.
• IT hardware: servers, GPUs, networking and cabling, whose supply chains extend into mineral extraction and electronics assembly.
• Professional and site services: legal, financial, technical, security, cleaning and facilities management.

4. Where the risk sits

We assess modern slavery risk by sector, geography and tier. Our current assessment identifies the following as the areas of highest risk:

• Construction labour, particularly migrant and agency workers, where recruitment fees, document retention and wage withholding are documented risks across the industry, including in Europe.
• Solar and battery component manufacturing, where parts of the global supply chain for polysilicon, and certain minerals, have been linked to forced labour.
• Electronics and IT hardware, where risk concentrates in raw-material extraction and assembly several tiers below our direct suppliers.
• Outsourced site services such as security and cleaning, where low-paid and agency labour is common.

We treat risk as higher where a project is in a jurisdiction with weaker labour enforcement, where labour is sourced across borders, or where a supplier cannot demonstrate visibility of its own supply chain.

5. Our policies

Our approach is set out in the following commitments, which apply to Eppur, its group companies and, through contract, to those who work for us:

• Zero tolerance. We will not knowingly work with any organisation that uses forced, bonded or child labour, or that engages in human trafficking, and we will end relationships where such practices are found and not remedied.
• Ethical recruitment. No worker on an Eppur project should pay for their job. We prohibit recruitment fees charged to workers, the retention of identity documents, and deductions or debt arrangements that tie workers to an employer.
• Supplier standards. Contractors and suppliers must comply with applicable labour law and with the principles of the International Labour Organization’s core conventions, and must flow the same requirements down to their own subcontractors.
• Speaking up. Anyone, whether employed by Eppur or by a supplier, can raise a concern in confidence with our management, without fear of retaliation, and we will investigate.

6. Due diligence

As our projects move from development into construction, we are embedding the following steps into how we procure and manage delivery:

• Pre-qualification of principal contractors and major equipment suppliers, including questions on labour practices, recruitment and supply-chain visibility.
• Contractual clauses in construction and supply agreements that require compliance with this statement, give us the right to audit and to receive information on the workforce and subcontractors, and allow us to suspend or terminate for breach.
• Site-level checks during construction, including verification that workers hold their own documents, are paid as contracted and have not paid recruitment fees.
• Enhanced scrutiny of solar, battery and IT hardware suppliers, including requests for supply-chain traceability to the level of raw-material origin where the risk warrants it.
• Cooperation with lenders, offtake partners and co-investors, whose own environmental and social standards frequently apply to our projects and reinforce ours.

7. Training

Our development, procurement and site teams are being trained to recognise the indicators of forced labour and trafficking, to understand the requirements in this statement, and to know how to escalate a concern. Training is refreshed annually and extended to new joiners.

8. Measuring effectiveness

From our next statement we will report on the following measures:

• The proportion of principal contractors and major suppliers that have completed modern slavery pre-qualification.
• The proportion of construction and supply contracts that include our modern slavery clauses.
• The number of site-level labour checks carried out, and their findings.
• The number of concerns raised through our speak-up channels, and how they were resolved.
• The proportion of relevant staff who have completed training.

9. Approval

This statement has been approved by the board of directors of Eppur and is signed on its behalf by: