JBR CAPITAL LIMITED

Policies described

Freedom of workers to terminate employment Freedom of movement Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents

Training described

Your whole organisation Your front line staff Human resources Executive-level staff Procurement staff

Worker engagement and working conditions

Your suppliers Workers within your organisation Businesses in your industry or sector

Social audits

Audit conducted by your staff

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app

Other monitoring

Shawbrook Policy requires due diligence on modern slavery and human trafficking risks. Relevant clauses in supplier contracts, with screening conducted at onboarding and throughout the relationship.

Demonstrated progress

Throughout 2025, we enhanced our approach to modern slavery risk by harmonising Group policies, strengthening contractual protections, and improving our Speak Up framework. Metrics were embedded into risk appetite and MI to support oversight. Internal assurance confirmed the framework is effective, alongside continued enhancement of due diligence in higher-risk sectors.

Reported risks and mitigations

• Risk: Supply chains extending to oversea jurisdictions that have a higher risk of modern slavery. Due diligence checks are carried out on suppliers including screening and contractual obligations.
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Group: Women Migrants Refugees Other vulnerable groups
• Location: United Kingdom
• Mitigation: Suppliers are predominantly UK based, however there is a risk that Modern Slavery could occur further down the supply chain. We do not have any current concerns. To mitigate this risk we conduct: Supplier Assessments: We conduct assessments of our suppliers above £5,000 to ensure they adhere to MS Regulation. We also conduct Risk Assessments and Assurance activity where necessary.
• Risk: Employees Due diligence checks carried out on employees at the point of onboarding and well-being checks conducted throughout period of employment.
• Area: Within your own operations
• Group: Other vulnerable groups
• Mitigation: Right to work/Reside checks are conducted at on boarding, screening of employees and well-being checks are made throughout employment.
• Risk: Outsourced Service Suppliers Oversight and monitoring carried out on third party suppliers and whistle blowing framework in place to ensure any conduct issues can be escalated.
• Tier: Tier 1 suppliers
• Location: United Kingdom India Poland
• Mitigation: Contractual obligations, screening, policies and site visits where appropriate. We also have a whistle-blowing framework in place enabling conduct issues to be escalated.