Modern Slavery & Human Trafficking Statement

This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015 (the “Act”).
This statement is made on behalf of Sumer Group Holdings Limited and each of its subsidiary undertakings that
met the turnover threshold under section 54 of the Act during the financial year. It sets out the steps taken
by Sumer Group Holdings Limited and its subsidiaries (together, “the Group”) during the financial year ended
30 June 2026 to prevent modern slavery and human trafficking within our business operations and supply chains.

The Act covers slavery, servitude, forced or compulsory labour and human trafficking. It requires organisations
above a specified size to publish an annual statement outlining the steps taken during the financial year to
ensure that modern slavery and human trafficking are not taking place within their business or supply chains.

1. Organisational Structure and Our Business

Sumer Group Holdings Limited is the holding company of a group of regional accountancy firms providing
accounting, tax, audit, advisory and business services largely across the United Kingdom and Ireland to
approximately 60,000 clients. Over 3,000 employees operate predominantly from offices in the United Kingdom,
Australia, United States of America, Poland, and South Africa.

We are committed to conducting business ethically and with integrity and expect the same high standards from
those we work with. Preventing modern slavery and human trafficking forms part of our wider commitment to
responsible business practices and effective corporate governance.

Given the nature of our business and the services we provide, we continue to consider the inherent risk of
modern slavery within our own operations to be low. However, we recognise that risks may exist within wider
supply chains and remain committed to taking a proportionate and risk-based approach to identifying and
addressing those risks.

2. Our Supply Chain

We are committed to maintaining a supply chain that is free from any form of slavery or human trafficking.
Our supply chain consists principally of professional and business services, information technology,
facilities management and office services, outsourced support functions and the use of subcontractors in
certain support activities.

We operate primarily within the UK and much of our supply chain is UK based. A small level of process
outsourcing for the UK business is performed by suppliers based outside of the UK including in India.

3. Policies and Governance

The Group maintains a zero tolerance approach to modern slavery and human trafficking.

During the reporting period we formally introduced and rolled out our Modern Slavery Policy across the Group.
The policy sets out our expectations of colleagues and supports our wider governance framework, alongside our
Code of Conduct and Speak Up arrangements.

Our policy reinforces the following principles:

• Child labour must not be used
• Forced, bonded or compulsory labour is prohibited
• Workers must be free to leave employment after reasonable notice
• Passports and other personal documentation must not be retained
• Debt bondage, including employment terms that trap individuals through unreasonable repayment obligations, is prohibited

4. Risk Assessment

We continue to believe that the risk of modern slavery occurring within our own workforce is low given the
nature of our business. However, we recognise that the greatest potential exposure exists within our supply
chain, particularly where goods and services may involve complex supply chains or multiple tiers of suppliers.

During the coming year, we will undertake a more structured risk assessment of our supplier population.
This will help us better understand where the greatest risks may exist and ensure that future due diligence
activities are targeted appropriately.

The assessment is expected to consider factors including:

• Geographic location of suppliers and their operations
• The nature of the products and services provided
• Sector specific risks
• Employment practices and, where relevant, the use of subcontractors

This work will provide the foundation for a more mature and risk based approach to supplier oversight in future years.

5. Due Diligence

During the reporting period, our focus has been on establishing the governance and awareness needed to support
a more structured approach to managing modern slavery risk.

While supplier due diligence remains an area of development, we have identified this as one of our key
priorities for the coming year. Building on the introduction of our Modern Slavery Policy and colleague
training, we intend to develop a proportionate, risk based due diligence process that supports the
identification of modern slavery risks within our supply chain.

6. Progress During the Year

During the reporting period we have focused on embedding the commitments made in our previous statement.

Key achievements include:

• Successfully rolling out the Group Modern Slavery Policy
• Delivering mandatory modern slavery awareness training for all new starters
• Providing refresher training to existing colleagues to reinforce awareness of modern slavery, the indicators to look for and how concerns should be reported
• Establishing the foundations for a more structured approach to managing modern slavery risk across the Group
• Launching our Group-wide Code of Conduct

These actions have strengthened awareness across the business and provide a solid foundation for the next
phase of our modern slavery programme.

7. Training and Awareness

Training continues to play an important role in supporting our approach to preventing modern slavery.

During the reporting period we introduced mandatory training for all new starters and delivered refresher
training to existing colleagues. The training helps colleagues understand what modern slavery is, recognise
potential indicators and understand how concerns should be reported through the appropriate channels.

We will continue to incorporate modern slavery awareness into our wider compliance training programme to
ensure colleagues remain aware of their responsibilities and the role they play in helping to prevent modern slavery.

8. Measuring Effectiveness

We recognise the importance of measuring the effectiveness of our approach to preventing modern slavery.
During the reporting period we monitored completion of mandatory modern slavery training and the operation
of our Speak Up arrangements.

As our programme matures, we intend to develop a broader set of performance indicators, which may include
training completion rates, the proportion of categories of suppliers subject to risk assessment and due
diligence, and the number and nature of any concerns raised and how they were addressed. We will report on
these measures in future statements to demonstrate progress year on year.

9. Priorities for the Coming Year

Over the next financial year, we will continue to build on the progress made by focusing on the areas that
present the greatest opportunity to strengthen our approach.

Our priorities are to:

• Undertake a formal, risk based assessment of our supplier population to identify suppliers that may present a higher inherent risk
• Develop and implement a proportionate supplier due diligence framework based on the outcomes of that assessment
• Introduce modern slavery considerations into supplier onboarding and ongoing supplier management processes where appropriate
• Continue mandatory training for new starters and refresher training for existing colleagues

By focusing on these priorities, we aim to further strengthen our ability to identify, prevent and respond
to the risks of modern slavery within our supply chain.

This statement was approved by the board of Sumer Group Holdings Limited on 23rd September 2026.

Warren Mead
Chief Executive Officer