UK Modern Slavery Act Statement – 2022

Encompassing financial year January 1, 2022 through December 31, 2022Egala Ltd (and all its operating subsidiaries, referred to herein as “EGALA” and/or “The Company”) is committed to respecting and valuing human rights on a global scale. Operating ethically and respecting employees, customers, and stakeholders are fundamental core values at the heart of EGALA’s corporate culture.

On October 29th, 2015, the United Kingdom Modern Slavery Act (“Act”) came into effect, putting anew focus on preventing slavery and human trafficking, Pursuant to the Act’s provisions, the following statement presents the analysis and steps EGALA has taken to prevent, detect, and remediate human trafficking and modern slavery it its global business.

Countries of Operation and Supply

‍EGALA is a leading global logistics company and its’ United Kingdom arm, consisting of EGALA, EGALA Limited, and EGALA Freight (UK) Limited, operate in all countries of the United Kingdom, offering integrated, end-to-end logistics solutions to deal with the complexities of today’s supply chains.

Organizational Structure and Supply Chains

‍Through EGALA’s lean culture and Operational Excellence, the Company addresses increased demand for operational efficiency and flexibility. EGALA’s ability to structure operations around customers’ KPIs and robust industry experience helps the Company to stay focused on specific logistics needs, deliver value-added service, and run its business in an environmentally conscious way. This Modern Slavery Statement applies to the activities of EGALA Group Plc and its affiliates.

EGALA Policies and Supply Chain Relationships

‍EGALA continually strives to clearly communicate its human rights policies and expectations to its customers, third party suppliers, and agents. As a global logistics company, EGALA does not inherently produce or manufacture products. In providing logistics services, it is imperative to ensure employees and third parties are alert to the relevant human trafficking legislation, and aware of EGALA's internal policies that promote human rights and the fight against the proliferation of human trafficking and modern slavery.

EGALA's Human Rights Compliance Program ("HRCP") is a risk-based program, focused on measures designed to eliminate human trafficking and achieve compliance with EGALA's Code of Business Conduct, the United Nations Guiding Principles on Business and Human Rights, U.S.

Government regulations and the Act.

‍EGALA’s HRCP communicates ethical business practice expectations and standards to our employees, customers, and suppliers. These are incorporated into Compliance Covenants, which are acknowledged by EGALA's high risk suppliers and agents. Additionally, the EGALA Code of Business Conduct outlines EGALA's continued commitment to promoting an ethical corporate environment and complying with all laws, including those prohibiting human trafficking, slavery, forced labour, child labour, and unfair wages.

Due Diligence & Auditing

‍As part of its' global compliance program, audits and reviews are conducted, including HRCP requirements, the specific review of risks, associated mitigating measures, and red flags. Further, EGALA has a dedicated risk-based third-party due diligence program to ensure that high risk third parties operate in compliance with all applicable laws (including corruption and human trafficking)and employs a global restricted party screening policy.

Training & Awareness

‍All EGALA managers and a selected employee population are required to complete an annual training covering HRCP, including red flags, and reporting potential concerns on human trafficking and forced labour. Additional human rights training is provided to employees when warranted. Risk Assessment and Continued Risk Management EGALA’s Global Trade Compliance ("GTC') team supports the Company in identifying and mitigating trade compliance risks. GTC has included human trafficking in its risk profile and diligence process. EGALA has established several reporting mechanisms, such as anonymous reporting, for employees to report human trafficking and forced labour concerns, which are diligently investigated.

Relevant policies

‍EGALA operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:Whistleblowing policy: EGALA encourages all its employees, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of EGALA. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. EGALA maintains a hotline and web-based reporting system, which allows individuals to report anonymously if desired in local language on any potential compliance concerns including concerns related to labour practices or breach of human rights.

Employee Code of Conduct: EGALA's Code of Conduct supports the Company’s employees in maintaining the highest standards of conduct and ethical behaviour when operating and managing its supply chain.

Recruitment and Selection Policy: EGALA uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. EGALA is committed to preventing the use of slavery in our business and our supply chain and encourage employees to look out for signs of slavery and report to relevant manager immediately, e.g., (a) physical and psychological abuse; (b) restricted movement; (c) poor living conditions; and (d) lack of personal belongings, such as their passport.

Performance indicators

‍EGALA has reviewed its key performance indicators (KPls). As a result, EGALA is:
- requiring all staff, supply chain managers and HR professionals to complete EGALA ' sGlobal Compliance Training comprising a module on modern slavery on an annual basis;
- developing a system for supply chain verification whereby EGALA evaluates potential suppliers before they enter the supply chain; and
- reviewing its existing supply chains whereby EGALA evaluates all existing suppliers.

Conclusion
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‍EGALA does not tolerate any violations of human rights laws by its employees and has established remedial measures contained in the HRCP that include suspension and/or removal of employees found in violation. EGALA will continue to update its policies and procedures as required to ensure that the Company maintains a high level of integrity and respect in its business operations as well as its supply chain.
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This statement has been approved by the Board of Directors of EGALA Limited.
Sjef Boekestijn, Member of the Board of Directors
EGALA Limited
Peter Boekestijn, Member of the Board of Directors
EGALA Limited