Modern Slavery Act Statement

Introduction

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Kpler is a fast-growing data intelligence company facilitating sustainable and efficient trade.

From numerous disparate and unstructured sources, Kpler creates intelligence that brings

transparency in dynamic markets characterised by opaque and incomplete information, such as

commodity, gas, power and maritime. Kpler delivers market research on the complete value

chain of commodities.

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As a global organisation, Kpler employs over 650 people and has offices in Austria, Belgium,

Cyprus, France, Germany, Greece, the UAE, the UK, the USA, and Singapore. With over 1,000

customers, Kpler’s market coverage spans over 40 sectors, including liquids, dry bulk, freight,

and inventories.

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Considering our role as a global leader in delivering Data-as-a-Service (DaaS) solutions, the

significant control we exercise over our direct operations, and the office based nature of our

workforce, we consider Kpler’s exposure to modern slavery risks inherently low. We are

committed to ethical business practices and maintaining the highest standards of integrity,

including ensuring that modern slavery and human trafficking have no place in our operations

and/or our supply chain.

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Our Policies and Processes in Relation to Modern Slavery

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Our Code of Conduct articulates the purpose, values, and principles guiding our work and

complement our employment policies to support our human rights responsibilities, including

workers' rights. These guidelines address modern slavery risks by ensuring fair pay above local

living wages and setting company-wide standards for hybrid and remote working issues. We

foster a diverse and respectful environment, prohibiting discrimination, bullying, and

harassment, as outlined in the business principles of our Code of Conduct.

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Our Whistleblower ‘Speak Up’ Policy offers employees and stakeholders an anonymous, secure

channel to report any concerns about unethical practices, including potential modern slavery or

forced labor. This policy enables us to address issues promptly, fostering accountability. We

actively encourage a "Speak Up" culture, where everyone feels empowered and supported to

raise concerns without fear of retaliation, contributing to a transparent and ethical organisational

environment.

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Kpler recognises that modern slavery, including forced labor, human trafficking, and other forms of

exploitation, is often linked to financial crimes, such as money laundering and illicit financial

activities. Kpler implements robust financial crime risk management practices, including

comprehensive policies on Anti-Money Laundering (“AML”) Policy, Anti-Bribery & Corruption

(“ABC”) Policy, Sanctions and Export Controls Policy, which are applicable to all customers,

suppliers, and contractors. As part of our due diligence processes, we conduct thorough

end-to-end compliance and credit checks on potential and existing business partners, particularly

those considered to be in high-risk jurisdictions. In addition to ensuring compliance with sanctions

and financial stability, this vetting process mitigates the risk of indirect involvement in exploitative

practices.

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Training and Awareness

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We understand the importance of improving our employees' knowledge and equipping them to

recognise and address modern slavery risks within our operations and supply chains. To

achieve this, we aim to enhance vigilance through interactive training sessions in order to:

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• Raise awareness of modern slavery and human rights issues;
• Enable employees to identify and assess potential risks in our supply chain; and
• Provide guidance on reporting concerns or escalating issues, supported by our

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Whistleblower ‘Speak Up’ Policy.

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We plan to continuously improve these programs by incorporating feedback, updating content

based on emerging risks, and using case studies to enhance learning where applicable. By

equipping our workforce with these resources, we aim to foster accountability and actively mitigate

modern slavery risks, upholding our commitment to ethical business practices.

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Review

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This statement constitutes as Kpler’s Modern Slavery Act Statement for the financial year ending

December 2024, which is made pursuant to section 54(1) of the Modern Slavery Act 2015. It is

made on behalf of Kpler Holding SA, and its subsidiaries, including: Kpler SAS, Kpler Ltd., Kpler Inc.,

Kpler DMCC, Kpler PTE. Ltd., Kpler GmbH, Kpler Power SAS, Kpler Finance SA, Kpler UK Joldco Ltd.,

Exmile Solutions L Td., Marine Traffic Operations SAS, Marine Traffic Applications Ltd., and Kpler

Germany GmbH.

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This statement was reviewed and approved by the Board of Directors on behalf of all of Kpler

Holding SA and all its subsidiaries. We will continue to report on our progress in future statements

to demonstrate our commitment to these critical issues.

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Further Document Details

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Version: v.02

Approval Date: September2025                                       Date for Next Review: September 2026

Risk Category: Medium Risk

Accountably Statement Owner: Legal, Risk & Compliance(LRC) Team