Modern slavery statement

At XLCC, we are committed to combatting modern slavery and human trafficking in all areas of our business and supply chains. We recognise our responsibility to uphold ethical practices and are committed to ensuring that slavery and human trafficking have no place within our operations or those of our partners.

Our business and supply chains

XLCC will never participate in exploitative business practices, including Modern Slavery. All XLCC employees are paid the Real Living Wage, are afforded at least the statutory minimum paid time off, and otherwise employed in accordance with all applicable laws. We always perform “Right-to-Work” checks to ensure that potential employees are in the UK legally, and therefore not subject to human trafficking or Modern Slavery.

XLCC is currently in a development stage where we are raising funds to build a factory in Hunterston to manufacture high-voltage subsea electricity cable for the renewable energy sector.

In the coming year the company’s focus is on developing our manufacturing and project delivery capabilities. Accordingly, our Modern Slavery risk exposure will be minimal and limited to the few external consultants and contractors we engage.

We are committed to working only with suppliers and partners who share our values of integrity and respect for human rights. Further details regarding how we deliver on this commitment are set out below.

Our policies

This Modern Slavery Statement is supported by the following policies:

• XLCC Code of Business Conduct: Requires our employees to adhere to high standards of ethical behaviour.
• Business Partner Code of Conduct and Ethics Addendum: Ensures our partners commit to ethical labour practices, including fair wages, safe working conditions, and zero tolerance for forced labour.
• Business Partner Due Diligence policy and process: Ensures screening and other due diligence is undertaken on suppliers and other business partners.
• Anti Bribery and Corruption Policy.
• Whistleblowing Policy.
• ERSG Policy.

Due diligence

We conduct due diligence to identify and mitigate risks of modern slavery in our supply chains, including:

• Supplier Qualification: All new suppliers are screened in accordance with our Business Partner Due Diligence policy to identify concerns with their employment practices.

• Ethical Commitment: Qualified suppliers are then required to commit to our Partner Code of Conduct and Ethics Addendum before engagement, which contains our requirements for sustainable and ethical supply chain management, including those relating to Modern Slavery.
• Contractual Agreements: Our template agreements for the purchase and supply of goods and services include requirements for supply chain compliance with all applicable laws, statutes, regulations, codes, and policies, including in relation to anti-slavery and anti-human trafficking.

• Audits and reviews: Periodic audits of high-risk suppliers will be performed to ensure compliance with ethical practices.

Training and awareness

All new employees are advised of their responsibilities in relation to modern slavery as part of their HR induction.

We provide regular training to employees, particularly those involved in procurement and supply chain management, to:

• Recognise signs of modern slavery.
• Understand their role in preventing unethical practices.
• Promote a culture of vigilance and accountability.

Looking ahead

XLCC remains committed to ensuring our business operations and supply chains are free from modern slavery. Over the next year, we aim to review more detailed metrics appropriate to the risks and management strategies for our Company to measure our performance.

Approval

This statement is made in accordance with Section 54 of the UK Modern Slavery Act 2015 and constitutes XLCC Limited’s slavery and human trafficking statement for the financial year ending 30 September 2025.  It has been approved by our Board of Directors. We take responsibility for this Statement and its related objectives and will review and update it in accordance with The Act.

Ian Douglas, CEO, XLCC
1 October 2025