SPIRIT ENERGY NORTH SEA LIMITED

Policies described

Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Other

Training described

Procurement staff

Worker engagement and working conditions

Your suppliers Professional auditors Workers within your organisation Workers within your supply chain Businesses in your industry or sector

Social audits

Audit conducted by your staff Third party audit arranged by your organisation Third party audit arranged by your supplier Announced audit

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app Through trade unions or other worker representative groups

Other monitoring

Deployment of remote worker surveys

Actions addressing ILO indicators

Other

Demonstrated progress

Over the past year, we have strengthened our human rights governance by updating our risk review with Slave‑Free Alliance, streamlining escalation for non‑compliance and modern slavery indicators, launching an ethical inspection programme to enhance supplier oversight, and expanding supplier due diligence across more categories and sites. In 2026, we will focus on continuous improvement of our modern slavery risk management and ensuring compliance with legislative developments.

Reported risks and mitigations

• Risk: Manufacture of electrical products – the manufacture of branded goods such as our Hive home solutions in China.
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers
• Group: Migrants
• Location: China Malaysia Thailand
• Mitigation: In 2025, audits were conducted on the ground at sites located in China, Thailand and Malaysia. We follow up with suppliers to close down any non-compliance or opportunities for improvement.
• Risk: Solar panels – specifically polysilicon production which is a key component in solar photovoltaic panels which occurs in China.
• Tier: Tier 3 suppliers and below
• Group: Migrants Other vulnerable groups
• Location: China
• Mitigation: We continue to co-sponsor an industry initiative with Solar Energy UK in partnership with Solar Power Europe, to develop a traceability framework. The initiative aims to improve transparency and raise standards. The procurement of polysilicon based solar panels continues to be a key area of focus for us and is subject to careful supplier selection and due diligence, as we continue in our efforts to establish transparency in the solar supply chain.
• Risk: Battery systems – the manufacture of battery systems and cells linked to raw material extraction and the associated critical minerals used therein.
• Tier: Tier 2 suppliers Tier 3 suppliers and below
• Group: Migrants Children
• Location: Congo (Democratic Republic) China India
• Mitigation: We will continue to work closely with leading battery system providers to ensure that the controls they have in place across the supply chain remain robust, proactive and support their suppliers to make positive contributions towards sustainable development.