Encyclis is an Energy-from-Waste group, which consists of facilities and projects owned and operated by  Rookery South Limited, Newhurst ERF Limited and Protos ERF Limited, Protos ERF CCS Limited and Encyclis (Walsall) Limited and Encyclis Limited, which are all companies in the Encyclis Holdco Limited group (together “Encyclis”). As we continue to grow, it continues to be important that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain.

This statement sets out the companies actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

Our commitment to ethical working and prevention of practices like modern slavery is key to our ethos and culture. As a leader in the energy from waste industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking and we continue to take our responsibilities very seriously.

Our organisation is absolutely committed to the aims of preventing slavery and human trafficking in its corporate activities, and ensuring that our supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Encyclis in the UK:

• Encyclis has two Energy from Waste (EfW) plants (Rookery South and Newhurst) plus two in construction (Protos and Walsall). Additionally, the company is working with the UK  government to deliver one of the first industrial-scale Carbon Capture plants in the UK at our site in Protos, Ellesmere Port. The construction of our new plants is sub-contracted and our Encyclis project managers ensure that construction meets the contractual terms and specifications which include anti-slavery protections and obligations to comply with the Modern Slavery Act 2015.

The following is the process by which Encyclis assesses our risks in relation to slavery or human trafficking:

• Each function or department owns a risk register which it updates periodically.
• We conduct a bi-annual risk review of our activities that includes input from our HR, Procurement, Operations and Legal Teams.
• This risk review is then assessed by our Executive Risk Committee and then reported to the Encyclis Group Audit & Risk Committee which in turn reports to the board of directors of Encyclis Holdco Limited.

Medium- and low-risk activities

We have worked and continue to work to mitigate our business activities and assess that any  ‘high-risk’ activities are suitably mitigated from a Modern Slavery point of view to allow the risks to
be considered medium- or lower- risk activities:

• In our construction activities, the companies that we sub-contract with to build our sites may themselves sub-contract certain activities to other parties. Whilst the majority of these activities are of a professional and technical nature there may be a greater risk in activities or roles that are unskilled. We believe that these activities represent a medium risk.
• Our fuel supply chain represents a medium risk (this includes the activities of businesses which supply and work with Encyclis plants; ‘fuel supply’ includes the delivery of lower volume and ad-hoc ‘spot waste’ and the operation of transfer stations and metal recovery facilities)
• Wider supply chain risk: as a medium-sized business we also purchase a range of services, products and consumables from local and small companies, for example:
  o outsourced services (like cleaning and catering); and
  o the use of third parties, particularly during maintenance ‘outage’ periods when larger numbers of contractors are required for range of activities such as specialist maintenance, industrial cleaning and catering.
• The recruitment of direct employees is now considered a low risk because of the direct control that we have over the recruitment and hiring processes routes that we use for our own staff (where we have direct control of the recruitment and employment processes and practices).

Responsibility

Responsibility for our anti-slavery initiatives is as follows:

• Policy, risk assessments, investigations/due diligence, and training: Human Resources
• Procurement policy, supplier selection, contracting and associated review / audit: Procurement team
• Fuel supply contracts and contract management: Business Development, Fuel and
  Commercial teams
• All activities are overseen by the Encyclis leadership team.

Relevant policies

We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

We continuously review and update all our policies.

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy. We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

• Employee code of conduct. Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour.

• The conduct of suppliers and companies we are working in partnership with. We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards required by law and provide adequate working conditions. Any serious violations of our supplier code of conduct may lead to the termination of the business relationship. Our Procurement team has introduced the following:

• • A standard supplier due diligence questionnaire which is completed by new suppliers as part of the tender process for Encyclis work which includes questions about their employment practices and requires them to sign a compliance statement before they are engaged, confirming that their practices are in line with our own zero tolerance approach to slavery or human trafficking; and
  • All of our standard terms of purchase and supply place contractual obligations on third parties that we engage with to ensure that they and their contractors will comply with the requirements of the Modern Slavery Act 2015.

• Recruitment approach. We recruit many staff ourselves and undertake preemployment right to work checks and use only specified, reputable employment agencies to source hard to fill roles and contractors. Specialist workers are engaged through a small number of agencies which allows us to have a closer working relationship which, in turn, helps to reduce the risk of slavery and human trafficking.

• Training. We have introduced a new Learning Management System in May 2025 which is allowing us to better plan and track the completion of training across the business and maintain a culture of compliance.

Improving our procurement processes

• During 2025, the Procurement and Legal team reviewed Encyclis Limited’s standard Terms & Conditions, (T&C’s), and implemented a new and updated version. The wording of the revised T&C’s document clearly states suppliers’ obligations in relation to the Modern Slavery Act 2015.
• Every Purchase Order for goods or services refers to Encyclis’ Terms & Conditions, ensuring all goods and services procured are covered by Modern Slavery Act 2015 commitments.
• We have updated our Purchase Order process to make reference to the updated Terms and
  Conditions and have also made these accessible on our external website. By doing this we
  aim to make clear to current and potential suppliers the standards that we expect of them.
• In Q2 2026, further proactive monitoring will be introduced. Encyclis’ Procurement team are publishing an Encyclis Supplier Code of Conduct, with full visibility on the Encyclis website. This Code of Conduct will further reinforce suppliers’ obligations in relation to Modern Slavery Act 2015 compliance. All Encyclis’ suppliers will be expected to sign up to these commitments. Any supplier who does not meet the requirements of the UK Modern Slavery Act 2015, or who does not sign up to the Code of Conduct, will not be permitted to trade with Encyclis until they satisfy these requirements.
• All Encyclis suppliers will be contacted to re-sign and confirm their compliance to the Code of Conduct annually, every January.
• We will conduct sample checks of our Construction partners’ approach to Modern Slavery and are running a rolling programme to update Fuel Supply contract’s terms of business for all new contract agreements, spot waste contracts and local suppliers.
• During 2026 we will undertake sample checks of our waste supplier Modern Slavery policies as part of our contract management processes.
• No incidents of modern slavery or human trafficking were reported across the Encyclis
  group during 2025.

Due diligence

We undertake due diligence when considering taking on new suppliers, and regularly review the performance of our existing suppliers. Our due diligence and reviews include:

• Evaluating the modern slavery and human trafficking risks of each new supplier as part of the procurement process by way of a supplier due diligence questionnaire and other ‘Know Your Client’ checks, and assessing supplier risk based on the Global Slavery Index of countries deemed to be most at risk of modern slavery;
• Taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through and requiring them to implement action plans;
• We are considering how external third-party advice may assist us in further improving our supplier due diligence.

Training and awareness

We periodically undertake modern slavery training with our Purchasing Managers and HR professionals who have a central role in minimising the risk of modern slavery occurring. We will also be extending this training to other groups of managers and supervisors who work on the ‘front line’ of our business and who interact more closely with our supply chain on a daily basis.

The training will be role-based covers areas including:

• Our business’s Procurement practices, how we assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available. In addition, how to identify the signs of modern slavery and human trafficking and what initial steps should be taken if modern slavery or human trafficking is suspected, and finally, how to escalate potential modern slavery or human trafficking issues to the relevant parties within our organisation and where to obtain external help and support on the issue.
• Staff also undertake modern slavery training by way of online video training modules. These seek to raise staff awareness of the existence of modern slavery and human trafficking and give tips on how to look out for the same.

We will continue to raise the awareness of Modern Slavery across the organisation and in our supply chain during the next 12 months. We have created a Modern Slavery Working Group that is monitoring the progress in implementing our approach to Modern Slavery.

Board Member approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Encyclis’ slavery and human trafficking statement for the year ending 31st April 2027.

This statement was approved on [5 May 2026] by Mark Burrows-Smith, Chief Executive, of behalf of The board of directors of Encyclis, who will review and update it annually.

Signature

Mark Burrows-Smith
CEO

Date:

Statement renewal date May 2027