Ethical Trading Policy

1. Purpose and Scope

The PPL Group (“the Group”) is committed to conducting its business ethically, responsibly, and with integrity across all operations, partnerships, and supply chains. This Ethical Trading Policy sets out the minimum standards we expect of ourselves, our suppliers, contractors, agents, and business partners.

This policy applies to all Group companies, employees, directors, temporary workers, consultants, suppliers, and third parties acting on behalf of the Group, regardless of geographic location.

2. Our Commitment

The Group is committed to:

Operating in compliance with all applicable laws, regulations, and standards.

Respecting internationally recognised human rights.

Promoting fair, safe, and inclusive working conditions.

Preventing unethical, illegal, or exploitative practices within our supply chain.

Acting with honesty, transparency, and accountability in all commercial dealings.

3. Legal and Regulatory Compliance

All parties engaged with the Group must comply with all applicable UK legislation and regulations, as well as relevant local laws in the countries in which they operate. This includes, but is not limited to:

• The UK Modern Slavery Act 2015.

• The Equality Act 2010.

• The Health and Safety at Work etc. Act 1974 and associated regulations.

• UK employment law, including the National Minimum Wage Act 1998 and Working Time

Regulations 1998.

• UK Bribery Act 2010.

• UK data protection legislation, including the UK GDPR and Data Protection Act 2018.

The Group also aligns its approach with internationally recognised standards, including the UN Guiding Principles on Business and Human Rights, the UN Global Compact, and the International Labour Organisation (ILO) Core Conventions.

Where differences exist between local laws and this policy, the higher standard shall apply.

4. Labour Standards and Human Rights

The Group is committed to upholding human rights in line with the UK Modern Slavery Act 2015 and the ILO Core Labour Standards.

4.1 Forced and Compulsory Labour

The Group prohibits all forms of forced, bonded, or involuntary labour, including human trafficking and modern slavery. Workers must not be required to lodge deposits or identity documents as a condition of employment.

4.2 Child Labour

Child labour is strictly prohibited. Workers must meet the minimum legal working age, and under no circumstances shall the Group tolerate practices that are harmful to the health, safety, or development of young people.

4.3 Wages and Benefits

All workers must be paid fairly and at least the legal minimum wage or industry benchmark, whichever is higher. Wages must be paid regularly and transparently, with no unauthorised deductions.

4.4 Working Hours

Working hours must comply with applicable laws and industry standards. Overtime should be voluntary and compensated appropriately.

4.5 Freedom of Association

The Group respects the rights of workers to freedom of association, collective bargaining, and lawful representation, in accordance with local laws.

5. Equality, Diversity, and Respect

The Group is committed to providing a workplace free from discrimination, harassment, and abuse.

All workers must be treated with dignity and respect, regardless of gender, age, disability, ethnicity, nationality, religion, sexual orientation, or any other protected characteristic.

6. Health, Safety, and Wellbeing

The Group expects all parties to provide a safe and healthy working environment by:

Identifying and managing workplace risks.

Providing appropriate training and protective equipment.

Maintaining safe facilities, equipment, and systems of work.

Taking proactive steps to protect physical and mental wellbeing.

7. Environmental Responsibility

The Group is committed to minimising the environmental impact of its operations and supply chain.

Suppliers and partners are expected to:

Comply with all applicable environmental laws and regulations.

Use resources efficiently and responsibly.

Reduce waste, emissions, and pollution where reasonably practicable.

Support sustainable sourcing and environmental improvement initiatives.

8. Ethical Business Practices

8.1 Bribery and Corruption

The Group operates a zero-tolerance approach to bribery, corruption, facilitation payments, and improper inducements, in accordance with the UK Bribery Act 2010. All business must be conducted transparently, ethically, and with appropriate controls in place.

8.2 Conflicts of Interest

Any actual or potential conflicts of interest must be disclosed promptly and managed appropriately.

8.3 Fair Competition

The Group is committed to fair competition and compliance with competition and antitrust laws.

Anti-competitive practices will not be tolerated.

9. Data Protection and Confidentiality

All parties must protect confidential information and personal data in accordance with applicable data protection laws and contractual obligations.

10. Supply Chain Expectations

The Group expects suppliers and business partners to:

Adhere to the principles set out in this policy.

Communicate these standards to their own suppliers and subcontractors.

Maintain appropriate policies, controls, and records to demonstrate compliance.

The Group reserves the right to assess, audit, or request information relating to compliance with this policy.

11. Reporting Concerns and Whistleblowing

The Group encourages the reporting of concerns relating to unethical, unlawful, or unsafe behaviour without fear of retaliation. This is consistent with the Public Interest Disclosure Act 1998. Concerns may be raised through internal reporting channels or via designated whistleblowing mechanisms.

12. Non-Compliance

Failure to comply with this policy may result in corrective action, suspension, or termination of business relationships, or disciplinary action for employees, depending on the severity of the breach.

13. Governance, Accountability, and Review

This policy supports the Group’s obligations under section 54 of the UK Modern Slavery Act 2015 (Transparency in Supply Chains). The PPL Group publishes an annual Modern Slavery and Human Trafficking Statement, which sets out the steps taken to prevent modern slavery and human trafficking within its operations and supply chains.

This Ethical Trading Policy should be read in conjunction with the Group’s Modern Slavery and Human Trafficking Statement, as well as related policies including those covering whistleblowing, procurement, health and safety, equality and diversity, and anti-bribery and corruption.

This policy is approved by the Group’s senior management and will be reviewed at least annually, or sooner if required by changes in legislation, risk profile, or business operations.

This policy is approved by the Group’s senior management and will be reviewed periodically to ensure it remains relevant, effective, and aligned with legal and ethical best practice.

14. Policy Ownership

Responsibility for this policy rests with the Group’s leadership team. Questions regarding its interpretation or application should be directed to senior management or the People & Compliance function.

Approved by: The PPL Group Leadership Team

Effective date: January 2026

Review date: January 2027