ID-Pal
Modern Slavery Statement

Introduction

ID-Pal Limited and its wholly owned subsidiary ID-Pal UK Limited together, “ID-Pal”), are committed to conducting business ethically and with integrity and to preventing modern slavery and human trafficking in our operations and supply chains. Although ID-Pal’s consolidated annual turnover is below the threshold requiring publication of a slavery and human trafficking statement under Section 54 of the Modern Slavery Act 2015, we have chosen to publish this statement voluntarily to demonstrate our commitment to respecting human rights and promoting responsible business practices.

Our business and structure

ID-Pal Limited is incorporated in Ireland and is the parent company of ID-Pal. The company owns 100% of ID-Pal UK Limited, which operates in the United Kingdom. ID-Pal offers businesses an easy-to-use online identity verification and AML screening service. Our procurement activities include the purchase of goods and services from suppliers located in Ireland, the UK, the USA and, where applicable, other jurisdictions.

Our commitment

ID-Pal has a zero-tolerance approach to modern slavery, forced labour, servitude, human trafficking and child labour. We are committed to:

• Acting ethically and with integrity in all business dealings.
• Seeking to work with suppliers who share our commitment to responsible employment practices.
• Complying with applicable employment, labour and human rights legislation in the jurisdictions in which we operate.
• Encouraging the reporting of concerns relating to unethical conduct or suspected labour exploitation.

Policies and governance

To support our commitment, ID-Pal maintains and operates policies and procedures which includes:

• Code of Conduct
• Equality, Diversity and Inclusion Policy
• Whistleblowing Policy
• ESG Policy

Responsibility for oversight of modern slavery risks rests with senior management and the Board of Directors.

Supply chain due diligence

ID-Pal seeks to assess and manage risks of modern slavery within its supply chain through proportionate measures, including:

• Conducting supplier due diligence where appropriate
• Working with reputable suppliers and service providers
• Including compliance obligations within supplier contracts where practical
• Reviewing supplier performance and addressing concerns when identified
• Considering labour and human rights practices when engaging new suppliers

Given the nature of our business and supply chains, we currently consider our exposure to modern slavery risks to be relatively low. Nevertheless, we recognise that no organisation is entirely free from risk and remain committed to ongoing vigilance.

Risk assessment

ID-Pal periodically reviews its operations and supply chain arrangements to identify areas where modern slavery risks may arise. Factors considered include:

• Geographic location of suppliers
• Industry sector risks
• Use of temporary or agency workers
• Reliance on subcontracting arrangements
• Nature of goods and services procured

Where elevated risks are identified, enhanced scrutiny may be undertaken.

Training and awareness

Relevant employees, particularly those involved in procurement, recruitment and supplier management, are encouraged to understand:

• The indicators of modern slavery and human trafficking
• Appropriate escalation procedures where concerns arise
• The Group’s expectations regarding ethical conduct and human rights

Management will review training requirements periodically to ensure continued awareness across the organisation.

Reporting concerns

Employees, contractors, suppliers and other stakeholders are encouraged to raise concerns regarding suspected modern slavery, human trafficking or other unethical conduct. All concerns will be treated seriously and investigated appropriately.

Looking forward

During the next financial year, ID-Pal intends to:

• Continue reviewing supplier due diligence processes
• Enhance awareness of modern slavery risks among relevant personnel
• Assess opportunities to strengthen supplier engagement on human rights matters
• Periodically review and update relevant policies and procedures

Approval

This statement has been approved by the Board of Directors of ID-Pal Limited and ID-Pal UK Limited.

Simon Montgomery
ID-Pal Limited

Sara West
ID-Pal UK Limited

Approved on 23 September 2026.