1. Our commitment

ESS does not tolerate modern slavery, forced or compulsory labour, human trafficking or child labour in any part of its business or its supply chains. This statement sets out the steps taken during the financial year and those planned for the year ahead.

2. Our structure and operations

ESS is a group of ESG and HSEC advisory companies operating from a head office in Dakar, Senegal, with registered entities in Côte d’Ivoire, Gabon, Gibraltar and Kazakhstan, and specialists working on client sites across Africa, Central Asia, Europe and Latin America.

We employ people directly and engage associate specialists on a project basis. Our own operations are professional services; the greater risk sits with the client projects we advise on and with the suppliers who support our teams in the field.

3. Our supply chains

Our direct suppliers are professional services, IT and software, travel and accommodation, vehicle hire and driver services, security services, office facilities and personal protective equipment. Field logistics, security and driver services in remote locations are the categories we treat as highest risk.

4. Policies

Our Code of Conduct, Human Resources Policy, Supplier Code of Conduct and Grievance and Whistleblowing Procedure together prohibit forced and child labour, require the right to freedom of association, and set out how concerns are raised and handled. ESS is a signatory to the UN Global Compact, whose Principles 4 and 5 address forced labour and child labour.

5. Due diligence

New suppliers in higher-risk categories are screened before engagement, and contracts require compliance with our Supplier Code of Conduct and a right to audit.

On client engagements, labour and working conditions are assessed against IFC Performance Standard 2 and, where lenders require it, the relevant EBRD, AfDB or Equator Principles requirements. Findings that indicate forced labour are escalated immediately.

6. Risk assessment and mitigation

We maintain a risk register covering country, sector and supplier category. Countries where we work that carry elevated forced-labour risk receive enhanced screening, including unannounced worker interviews on projects where ESS holds a monitoring role.

7. Training

All employees complete Code of Conduct training on joining and refresher training annually. Specialists conducting social assessments receive additional training on identifying indicators of forced labour, trafficking and child labour during site work.

8. Measuring effectiveness

We track: the proportion of higher-risk suppliers screened; the number of assessments including a labour-conditions component; the number of forced-labour findings raised and closed on client projects; the number of grievances received through our channels and the time taken to respond, against our 72-hour commitment.

9. Raising a concern

Anyone — employee, supplier, community member or client — can report a concern through our whistleblowing channel, anonymously if preferred. Reports are entered in the ESS Grievance Register and acknowledged within 72 business hours.

10. Approval

This statement is made for the financial year ending July 2026 and was approved by ESS on 15 Sept 2026.

Adrian Mill, Managing Director, for and on behalf of all operating ESS (Environmental and Social Sustainability) entities.