Modern Slavery and Human Trafficking Statement

Financial year ending 31st May 2025

This statement is published on behalf of K3 Advisory Group Limited and its corporate subsidiaries and affiliates (“K3”) which in the UK encompass the following entities in the list here with reference to section 54(1) of the Modern Slavery Act 2015 (the “Act“):

A full list of UK entities in K3 Advisory Group is below.

Chief Executive Officer’s statement

K3 is committed to acting ethically and with integrity in all its business dealings and relationships and to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in its own business or in any of its supply chains.

K3 is alert to the risks posed and has implemented internal mandatory policies and procedures aimed at good conduct and business ethics from our people and in our business dealings which are described more fully below.

K3 opposes slavery and human trafficking in all its forms including child labour and will not conduct business with organisations which, upon enquiry, fail to properly explain their business or whose supply chain is not deemed equivalent to the group’s own high standards.

K3’s processes and controls to identify and combat slavery and human trafficking have been enhanced over the past financial year as described below.

About K3 Advisory Group – Our Organisational Structure

K3 is a multi-disciplinary business advisory firm which delivers professional services to clients, including corporate finance and business sales, tax advisory, insolvency and restructuring, accounting in support of disputes and valuations, data and technology services and financial services.

In the United Kingdom, K3’s has offices across the UK with its key locations in Manchester and London, with offices also in Europe and Asia.

At the time this statement was published, the group has over 1007 employees located in the UK, of which 154 hold senior management positions. The vast majority of the group’s employees are in professional services business advisory and supporting roles.

In addition to a centralised group board and management team, we operate centralised functions such as Finance, Legal, Compliance and Operations which exercise oversight of all of our businesses wherever they are located. Together, these functions under my oversight manage the processes we have in place to combat slavery and human trafficking risk. We also operate centralised governance, with policies and procedures being applicable to all our group companies and the staff they employ.

No industry is immune to modern slavery and human trafficking which can be hard to detect and can look like “ordinary work”. As an organisation it is therefore critical to assess the risks relative to the business services we provide and the way we operate.

Business risk

Maintaining our business integrity and high ethical standards is fundamental to K3’s culture and our working relationships. We are committed to ensuring that our ongoing business operations continue to be free from modern slavery and human trafficking.

We endorse the transparency that the Modern Slavery Act encourages and the professional referrers we work with are subjected to due diligence processes, which obligate them to respect human rights including the elimination of slavery and human trafficking within their business operations and supply chains. Contractors and consultants working on site at our premises also have the right to protection against slavery or human trafficking as part of the Group’s Whistleblowing Policy.

We have not in the past financial year identified any instances of modern slavery or human trafficking in our organisation.

Supply chain risk

Given the nature of the Group’s business, we have determined that our primary area of focus for the purposes of addressing the risk of slavery and human trafficking in our business lies in our supply chain rather than within our primary businesses.

The supply chain includes both external suppliers and professional service advisers (i.e. lawyers, accountants) that we instruct on assignments. We expect all of our suppliers and advisers to be similarly opposed to slavery and human trafficking.

External suppliers provide the following services to the Group: cleaning and catering, hospitality, IT equipment, software, consultancy, payroll, audit, legal services, office consumables such as stationery, office fit-out and maintenance. Most of the suppliers that we deal with are firms based in the UK. K3 has a preference for working with a smaller number of preferred suppliers and professional advisers and we have long-term relationships with many, although we do not consider ourselves dependent on any. During the last financial year we have developed a new procurement policy to be implemented in the coming financial year which incorporates enhanced supplier due diligence. This means that any new key or material supplier to K3 is subject to enhanced due diligence in the on-boarding process which requires disclosures to be made relating to slavery and human trafficking. We will continue not to work with suppliers who do not share our values and who cannot demonstrate with reasonable confidence that they do not have modern slavery or human trafficking in their organisations.

We have not in the past financial year identified any instances of modern slavery or human trafficking in our supply chain.

Policies and training

To ensure all staff are aware of and have a clear understanding of the risk of modern slavery and human trafficking within our business, we require all staff regardless of their seniority to confirm they have read and understood this statement as part of the firms’ Annual Policy Declaration. We actively track this policy acceptance.

In the past financial year we have issued a new Corporate Social Responsibility Policy which details how, amongst other things, we are committed to social responsibility and good conduct including ensuring our business operations continue to be free from slavery and human trafficking.

The Group’s Whistleblowing Policy is also available for our employees, consultants and contractors to report anything in breach of this policy.

We invest in educating all our staff. Training courses include slavery and human trafficking and associated risks in our business and supply chains, training aimed at combatting financial crime including anti-bribery and corruption and an anti-harassment policy in addition to other conduct training, all designed to drive positive behaviours in our organisation and an inclusive and respectful, speak-up culture.

Continuous review and improvement

The size and nature of our business has grown considerably over recent years and we have added several new divisions, all in the professional services space. We will continue to review our working practices, train our colleagues and review our external supplier and adviser relationships with regard to opposing slavery and human trafficking to ensure that they remain robust and effective. We will continue to respond to Modern Slavery Act information requests from our clients.

Board Approval

This statement was approved by the Board of K3 Advisory Group Limited.

Michael Cauter

Chief Executive Officer

On behalf of the board of K3 Advisory Group Limited