Modern Slavery Statement

Introduction

This statement is made pursuant to Section 54 of the United Kingdom Modern Slavery Act 2015. It sets out the steps that Kaelo Global Limited and its affiliated entities (collectively, "Kaelo Global") have taken during the financial year ending 31 December 2025 to ensure that modern slavery and human trafficking are not taking place in our business operations or supply chains.

Kaelo Global is a multi-jurisdictional advisory firm headquartered in Meydan Free Zone, Dubai, with additional offices in Singapore and Seychelles. We provide advisory services across strategic consulting, capital and investment advisory, regulatory and compliance advisory, and related professional services. We recognise that modern slavery is a serious global issue that affects every industry and every geography, and we are committed to conducting our business in a manner that prevents the exploitation of workers and upholds the dignity and rights of all individuals throughout our operations and supply chains.

Our Structure and Operations

Kaelo Global operates through corporate entities in Dubai (Meydan Free Zone), Singapore, and Seychelles. Our workforce consists primarily of professional advisory staff — analysts, associates, consultants, and senior advisers — employed directly by Kaelo Global entities under employment contracts that comply with the labour laws of each respective jurisdiction. We do not employ workers in manufacturing, agricultural, or other sectors traditionally associated with the highest prevalence of forced labour.

However, we recognise that our status as a professional services firm does not exempt us from modern slavery risk. The jurisdictions in which we operate — particularly the Gulf and certain African markets where we provide advisory services — are identified by international bodies as regions where migrant labour exploitation, forced labour, and trafficking risks exist across sectors including construction, domestic services, and hospitality. While our direct workforce faces lower risk, our supply chain and the broader business environments in which we operate require active monitoring and due diligence.

Supply Chain Due Diligence

Our supply chain consists primarily of professional service providers (legal, audit, technology, and consulting firms), office accommodation providers, technology vendors, travel and hospitality service providers, and facilities management companies. We have identified the following categories within our supply chain as carrying elevated modern slavery risk: facilities management and cleaning services (due to the prevalence of migrant labour in these sectors in the Gulf), construction and fit-out services (where our offices undergo renovation or expansion), and travel and hospitality services (where we engage hotels, airlines, and event venues in jurisdictions with identified labour exploitation risks).

For these elevated-risk categories, we conduct enhanced due diligence that includes: verification that suppliers comply with applicable labour laws, including minimum wage requirements, maximum working hour restrictions, and leave entitlements; confirmation that suppliers do not engage in practices associated with forced labour, including the confiscation of identity documents, the imposition of recruitment fees on workers, or the restriction of workers' freedom of movement; and contractual requirements that suppliers maintain their own modern slavery due diligence processes and report any identified or suspected instances of modern slavery to Kaelo Global promptly.

Risk Assessment

We conduct an annual risk assessment of modern slavery risk across our operations and supply chain. The risk assessment methodology considers: the geographic risk profile of each jurisdiction in which we operate or procure services, using indices published by the Global Slavery Index, the International Labour Organization, and the US Department of State Trafficking in Persons Report; the sectoral risk profile of each supplier category; the nature and duration of the supplier relationship; and the degree of control or influence we exercise over the supplier's operations.

The most recent risk assessment identified no confirmed instances of modern slavery within our operations or supply chain. However, it identified facilities management and hospitality services in the Gulf as the highest-risk categories and recommended continued enhanced due diligence, including periodic site visits and worker interviews, for suppliers in these categories. These recommendations have been implemented and are monitored by the firm's Compliance function.

Policies and Procedures

The following internal policies support our approach to preventing modern slavery: our Code of Conduct, which sets out the ethical standards expected of all Kaelo Global personnel; our Procurement Policy, which requires modern slavery due diligence for all new supplier engagements and contract renewals; our Whistleblower Policy, which provides confidential reporting channels for any person — employee, supplier, or third party — who becomes aware of actual or suspected modern slavery in connection with Kaelo Global's operations; and our Human Rights Policy, which affirms the firm's commitment to respecting internationally recognised human rights standards including the Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the UN Guiding Principles on Business and Human Rights.

All new supplier contracts include modern slavery clauses requiring the supplier to: comply with all applicable modern slavery laws; not use forced, bonded, or compulsory labour; not engage in human trafficking; allow Kaelo Global or its agents to conduct audits of the supplier's operations to verify compliance; and immediately notify Kaelo Global of any identified or suspected instances of modern slavery in the supplier's operations or supply chain.

Training and Awareness

All Kaelo Global personnel receive training on modern slavery awareness as part of their induction programme. This training covers: what modern slavery is and how to recognise its indicators; the firm's obligations under the Modern Slavery Act 2015 and equivalent legislation; the firm's internal policies and procedures for preventing modern slavery; and how to report concerns through the firm's whistleblowing channels.

Personnel with procurement responsibilities receive additional, role-specific training on conducting modern slavery due diligence, evaluating supplier compliance, and responding to identified risks. This training is refreshed annually and updated to reflect changes in legislation, best practice guidance, and the findings of our annual risk assessment. Training completion is tracked and reported to the Board as part of the firm's compliance monitoring programme.

Measuring Effectiveness

We measure the effectiveness of our modern slavery prevention efforts through the following key performance indicators: the percentage of new supplier contracts incorporating modern slavery clauses (target: 100%); the percentage of elevated-risk suppliers subject to enhanced due diligence (target: 100%); the completion rate of modern slavery training across all personnel (target: 100%); the number of modern slavery concerns reported through our whistleblowing channels; and the outcomes of our annual risk assessment. These metrics are reported to the Board annually and are published in this statement to maintain transparency with our stakeholders.

Board Approval

This statement has been approved by the Board of Directors of Kaelo Global Limited and is signed on behalf of the Board. It will be reviewed and updated annually in accordance with Section 54 of the Modern Slavery Act 2015. Enquiries regarding this statement should be directed to compliance@kaeloglobal.com.