MODERN SLAVERY STATEMENT

Our Commitment

This Modern Slavery Statement applies to all workers, employees, contractors and suppliers of Elite globally including Sky UK New Co Limited and its UK affiliates (collectively, “Elite”). Elite and its global companies are committed to conducting business ethically, responsibly, and in compliance with all applicable laws addressing modern slavery and human trafficking. Elite does not tolerate in any way any form of forced labor, child labor, servitude, or human trafficking in our operations or supply chain. Our commitment forms part of the standards set out in our Elite Global Code of Conduct and other internal policies, which outline expectations for lawful and ethical behavior across the company.

Our Organization and Supply Chain

Elite is a global financial management technology and services provider serving the legal industry. Our operations are headquartered in the United States, with employees and operations supporting clients in the United Kingdom and other jurisdictions. Our supply chain primarily consists of reputable technology, cloud hosting, and professional services vendors. These sectors generally present a lower inherent risk of labor exploitation compared to other supply chains, however, we remain vigilant and take reasonable steps to ensure our suppliers operate ethically. Our procurement and onboarding policies, processes and controls are designed to identify, manage and mitigate these risks throughout the supply chain as well as employee base.

Responsibility

Responsibility for upholding our anti-slavery commitments rests with all Elite employees, contractors, and suppliers. We expect all individuals and organizations acting on our behalf to promote ethical and lawful employment practices. Elite prohibits the use of forced or compulsory labor, defined as any work or service performed involuntarily or under threat of penalty.

Reporting concerns

Elite maintains a Global Whistleblowing Policy, which provides employees and third parties, including suppliers, with multiple confidential reporting channels, including an external hotline and web intake system, and strictly prohibits retaliation for good faith reporting.

Supplier Standards and Due Diligence; Our Remediation Approach

Elite expects its suppliers to comply with all applicable labor and human rights laws and to operate in a manner consistent with our ethical standards. This includes ensuring that employment is freely chosen, workers are not charged recruitment fees, and no forced or compulsory labor is used, no child labor or exploitation is present.

As part of our supplier onboarding and contracting processes, Elite may request information and, where appropriate, include contractual provisions requiring compliance with applicable laws relating to labor practices, human trafficking, and modern slavery.

Every person in our organisation plays a role in preventing modern slavery within our business and supply chains. To support this commitment, we have established a comprehensive suite of policies, frameworks and training programs aimed at fostering a culture of responsibility. Where Elite identifies conduct inconsistent with this Modern Slavery Statement or with applicable laws, we may suspend or terminate our relationship with the supplier. Elite will take steps appropriate to the nature and severity of the issue, including escalation to legal or regulatory authorities where required. Any Elite employee who violates this policy or relevant laws will be subject to disciplinary action, up to and including dismissal.

Training and Awareness

Elite is committed to fostering awareness of modern slavery and human trafficking risks. Employees are required to comply with the Elite Global Code of Conduct, which sets expectations for ethical behavior and compliance with applicable laws, and attend all required ethics and compliance trainings. Elite continues to consider appropriate approaches to awareness raising in this area as part of its broader ethics and compliance programs.

Approval

This Modern Slavery Statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes Elite’s slavery and human trafficking statement for the financial year ending 2025.

Signed on behalf of Sky UK New Co Limited and its UK affiliates by:

Mark Dorman Chief Executive Officer