MODERN SLAVERY POLICY

A - ORGANISATION

This statement applies to all companies within and associated to Samy Group Limited including Samy Ltd, Samy Services Ltd, Samy (County) Ltd, Samy Investments Ltd, Stayte Energy Ltd. and MPK Properties Ltd referred to collectively in this statement as the ’Group’. The information included in the statement refers to the financial year 2025.

B - DEFINITIONS

The Group considers that modern slavery encompasses:

• ✅ Human trafficking.
• ✅ Forced work, through mental or physical threat.
• ✅ Being owned or controlled by an employer through mental or physical abuse or the threat of abuse.
• ✅ Being dehumanised, treated as a commodity, or being bought or sold as property.
• ✅ Being physically constrained or to have restriction placed on freedom of movement.

C - COMMITMENT

The Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Group understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Group does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant UK employment legislation in and in many cases exceeds those minimums in relation to its employees.

D - ORGANISATIONAL STRUCTURE

The Samy Group of companies, can trace its origins back to 2009, has grown organically to become one of the UK’s leading independent retail operators of convenience forecourts and standalone convenience stores. The Group’s stores are supplied through trading agreements with FTSE 50 wholesalers (Tesco Stores Ltd & W M Supermarkets Ltd). The Group is now one of Booker Retail Partners (GB) Ltd and WM Morrisons’ Supermarkets (WMS) largest independent customers by wholesale volume.

The Group also has a strong reputation with Motor Fuel Group (MFG) being one of their leading Commission Operators of their forecourts. The Group Structure is attached at Annex A. The Group sit sunder one holding Company Samy Group Ltd and is controlled by an operating board. The Group and its associated Companies have a single shareholder.

The Group operates via multiple sites throughout England the United Kingdom with a particular focus in the Northeast & Yorkshire, Birmingham & the south Midlands & East of England.

The main activity conducted by the Group is the sale of convenience groceries & fuel. The Group performs the sale of the aforementioned goods both in store/sites and via its Comm Ops arrangement with MFG. Demand for our product is generally consistent throughout the year and although there is seasonality we adjust store hours to accommodate.

The Group have a strict recruitment regime for directly employed members of staff. Where the required suite of checks is made on employees their RTW and status. The labour supplied to the Group in pursuance of its operation is generally on a contract basis with small third-party suppliers to perform fit-out or delivery contracts. These operate throughout the Samy estate. It’s important to note the Group does not operate outside of the UK nor currently in Scotland or Northern Ireland.

E - SUPPLY CHAIN STRUCTURE

We are also committed to ensuring that there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our colleagues and all our contractors, suppliers, and other business partners. We expect that our business partners will hold their own suppliers to the same high standards.

In order to fulfil its trading activities, the Group’s main supply chains include those related to Tesco Stores Ltd & Wm Morrison Supermarkets Plc. As well as fuel supply companies such as Valero and Shell & BP. The Group also has relationships with Retail delivery partners which we monitor closely. We understand that these Group first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers.

F - ORGANISATIONAL POLICIES

The Group has the modern slavery policy which further define its stance on modern Slavery.

G - ASSESSING AND MANAGING RISK

The Group considers its main exposure to the risk of slavery and human trafficking to exist in it supply chain due to the complex variety of the products that are sourced. The Group is reliant on the work undertaken by its tier one suppliers in Tesco Stores Ltd & Wm Morrisons Supermarkets Ltd.

The areas of enhanced risk are: -

• ✅Construction and Fit-Out suppliers; and
• ✅Retail Delivery Partnerships (e.g. gig-economy courier services such as Uber Eats).
• ✅Retail Labour Providers (erg catering, cleaning, security, stocktaking, and merchandising suppliers).

In general, the Group considers its exposure to direct slavery/human trafficking to be limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

H - DUE DILIGENCE IN RELATION TO MODERN SLAVERY

The Group conducts due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

I - TRAINING

The Group has only recently crossed the requirement for training and a policy. It is developing training at present but provides the following training to staff to implement its stance on modern slavery.

Colleagues can report concerns about any conduct that they think might be a breach of the law, our Values. This whistleblowing process is not for reporting minor grievances or HR issues. For those issues, colleagues should speak with your line manager.

If colleagues cannot talk directly to the person whose conduct is causing concern, you are encouraged to raise the matter with your line manager first. If you are unable to raise your concern with your line manager or they take no action, you must raise your concern using any of the following channels:

• ✅Speak directly with a member of your head office team.
• ✅Contact the Director, or a member of the Leadership Team,

Colleagues are made aware/trained in the Indicators of Modern Slavery

As a Samy colleague it is important to be aware of the indicators of modern slavery. If you see any of these signs, you could be witnessing a case of modern slavery:

• ✅Victims may often appear frightened and may not interact outside their immediate group.
• ✅Due to lack of money to buy food, they may be malnourished and thin.
• ✅They may appear to have health problems or appear bruised from having been beaten by their exploiters.
• ✅A victim could have smelly or dirty clothes, as they do not have enough money to buy or wash clothes.
• ✅They may often revert to one controlling individual to translate for them when questioned.
• ✅Victims often have few or no personal belongings or identity papers and passports as exploiters will have taken them.
• ✅Victims’ bank accounts and access to money will be controlled by the exploiters.

If a role requires a visit to a customers or supplier sites, colleagues are made aware of how they could spot and help detect modern slavery. Modern Slavery is closer than you think, and you may well encounter it in your life outside of work. Modern Slavery can occur with supply chains or within your personal everyday life and interactions.

To assist us to eradicate modern slavery within our business operations and those of our supply chain, we hugely appreciate any insight you might have in this regard. If you detect or suspect modern slavery in any part of our business operations or those of our suppliers, please do report your suspicions.

J - MONITORING AND EVALUATION

The Group has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Group or its supply chains.

The Group has only recently been formed and is exploring the most effective way of monitoring and evaluating its approach to modern slavery. The Group is reassured that its exposure is limited given that the vast majority of its suppliers are significant operators.

Whistleblowing

The Group encourages all colleagues to speak up regarding any concerns of Modern Slavery incidents, or suspected incidents, breaches of policies, anything unlawful, or deliberate concealment of information relating to these things.

If you suspect that a breach of this policy has occurred or may occur in the future, you can also speak to your line manager, head office or Director.Phone: 07760387933 or info@samyltd.com.

K - STEPS

The Group has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Group has taken the following steps to ensure that modern slavery is not taking place:

• ✅ Reviewing our supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery.
• ✅ Reviewed all RTW, bank and personal details with colleagues within the business.
• ✅ Management has undertaken 1-2-1 checks with colleagues & suppliers at store level;
• ✅ and measures are being developed to identify and assess the potential risks in its supply chains.
• ✅ training to be undertaken to embed a zero-tolerance policy towards modern slavery.

L - MODERN SLAVERY COMPLIANCE OFFICER

The Group has a Modern Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Group obligations in this regard.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.