Financial year: Year ended 31 December 2025

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and outlines the practical steps Eleco plc (“Eleco” or the “Group”) has taken during the financial year to prevent modern slavery and human trafficking within its operations and supply chains in line with the latest UK Government guidance.

1. Our business and structure

Eleco plc is a UK based, AIM-listed international software group providing solutions to the built environment, construction, asset management and engineering sectors. The Group operates through a number of subsidiaries across the UK, Europe and North America, employing people directly and working with third party suppliers and partners to deliver our products and services.

2. Our policies

Eleco has a zero-tolerance approach to modern slavery and human trafficking. Our approach draws on board-level oversight and robust supplier codes of conducts.

In 2025, Eleco completed the following actions:

• Reviewed our Anti Slavery and Human Trafficking Policy
• Enhanced oversight through the ESG Committee, which reports directly to the Board
• The publishing of this modern slavery statement in line with UK Guidance and acknowledgement of the need for “continuous improvement” and more granular disclosure

Our commitment is set out in our Anti-Slavery and Human Trafficking Policy, which applies to all employees, directors, officers, contractors, agency workers, consultants and business partners. The policy reflects our commitment to act ethically and with integrity in all business relationships and to implement and enforce effective systems and controls to mitigate the risk of modern slavery within our operations and supply chains.

Related policies and frameworks that support this commitment include:

• Eleco Group Controls Handbook
• Eleco Group Policies:
  • Code of Conduct
  • Equality, Diversity and Inclusion
  • Whistleblowing Policy
  • Recruitment Policy
  • Employment Handbook
• Supplier onboarding protocols

3. Risk assessment and due diligence

As our portfolio of products support end to end building lifecycle and asset management, our operations shape how we identify and manage modern slavery risk, particularly in relation to third party service providers and suppliers.

We have identified the following potential risks:

• Recruitment agencies
• Facilities and office services providers, including cleaning, security and maintenance
• Software development contractors (domestic and international)

We consider these indirect risks to be real but manageable, requiring structured assessment and monitoring. We achieve that through the following mitigating activities:

• Assess modern slavery risks as part of supplier onboarding and renewal processes, proportionate to the nature of the supplier relationship
• Include appropriate contractual provisions requiring suppliers to comply with applicable anti slavery and human trafficking laws
• Expect suppliers to hold their own suppliers to equivalent standards
• Request recruiters undertake mandatory right to work checks on potential recruits.
• Undertake a proportionate supplier risk assessment – considering geography and labour risk activities
• Awareness training for relevant employees

4. Training and awareness

Eleco is committed to ensuring that relevant employees understand the risks of modern slavery and how to identify and report concerns including risk factors and non-compliance indicators. Awareness of our Anti-Slavery and Human Trafficking Policy is supported through internal communications and, where appropriate, training for employees involved in procurement, supplier management and recruitment.

5. Reporting concerns

All employees and others working on Eleco’s behalf are encouraged to report any concerns related to modern slavery or human trafficking. Concerns can be raised through line management, HR, or via the Group’s whistleblowing reporting routes which are published on the company website. Reports are taken seriously and investigated appropriately, with protection available for those who raise concerns in good faith.

6. Effectiveness and continuous improvement

Eleco keeps its approach to modern slavery under review as part of its wider ESG and governance framework. Oversight of modern slavery risk, policy effectiveness and related actions sits with the Group’s ESG Committee, which reports to the Board. We continue to assess the effectiveness of our policies and processes and will enhance our approach over time, taking account of regulatory developments, best practice and the evolving nature of our business and supply chains.

As part of continuous improvement and monitoring, the ESG committee will discuss relevant Key Performance Indicators (KPIs) relevant to Eleco and reporting guidance from the UK government.

This may include the following:

• Number of whistleblowing reports related to modern slavery (e.g. zero)
• % of employees who have read and accepted the Anti Slavery & Human Trafficking Policy
• Number of relevant employees trained
• Number of suppliers assessed during onboarding or renewal

7. Approval

This statement was approved by the Board of Directors of Eleco plc on 24 April 2026.