Modern Slavery Act Statement

Introduction

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.

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.

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.

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;

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● Enable employees to identify and assess potential risks in our supply chain; and

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● Provide guidance on reporting concerns or escalating issues, supported by our 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 LTd., Marine Traffic Operations SAS, Marine Traffic Applications Ltd., and Kpler Germany GmbH.

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.01

Approval Date: February 2025 Date for Next Review: February 2026 Risk Category: Medium Risk

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