Modern Slavery Statement

Introduction

This statement sets out Civica's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

Civica Group Limited, including its associated and subsidiary companies, recognises that it has a responsibility under the Modern Slavery Act 2018 (Australia) and Modern Slavery Act 2015 (United Kingdom), to take a robust approach to slavery and human trafficking and we are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.

Organisational Structure and Supply Chains

We are a global leader in software for public services, providing software and digital solutions supporting more than 100 million citizens . Headquartered in London, we have employees based across the UK Australia, New Zealand, Singapore, India, Canada, and the USA. Our supply chains are based within the countries in which we operate. Our parent organisation is Civica Group Ltd.

We design, build and deploy software and professional services. Our customers are both public and private sector organisations, sand include local councils, national government, NHS and private healthcare proviers, school and libraries amongst others.

Civica has a complex supply chain however, this can be categorised in four key areas ICT Services, ICT hardware, Indirects and Property. Civica works primarily with key market leaders such as Microsoft, Amazon Web Services, HP, and Cisco, where downstream supply chains are adequately vetted, monitored and reported. When onboarding new suppliers, we deploy a specific set of processes to ensure the supply chain is compliant with risks such as location, country of origin, product type, and ensure evidence is available of adequate published statements and modern slavery policies. We complete annual modern slavery assessments as part of our ongoing supplier assurance.

Relevant Policies

We operate the following policies to ensure we understand how to identify modern slavery risks and ensure we have identified steps to prevent slavery and human trafficking in our operations:

• HR Policy - We promote our Modern Slavery Policy within our Team Handbook which is provided to all employees upon commencement of employment, and is permanently accessible through our intranet.
• We have zero tolerance of any threat of physical or sexual violence, harassment, or intimidation against employees and their family, or close associates.
• Our policies are clearly defined and communicated to all employees.
• We undertake an annual salary review to ensure all our employees are treated fairly and equally and are paid above the Legal National Minimum Wage in each region
• Our employees will not be forced to work more than the number of hours permitted in law, and normal working hours will not exceed 48 hours per week average unless with express agreement of the employee.
• Purchasing Policy – The organisation is committed to conducting all Purchasing activities in a fair, objective, and transparent manner that satisfy the requirements of both external and internal accountability, governance, and controls.
• We have a comprehensive set of corporate policies and statements that provide direction and guidance to support fulfilment of our legal, financial, and Environmental, Social and Governance (ESG) obligations.
• Emphasis is placed on selecting suppliers, service providers, partners and contractors that ensure compliance with laws, legislation, and regulations, and that demonstrate high standards in terms of information security, ESG, sustainability, Corporate Social Responsibility (CSR), business integrity and ethical business behaviour. Furthermore, we look for suppliers that display high standards for health & Safety, human rights, labour working conditions, and Diversity, Equity, and Inclusivity (DE&I).
• Recruitment Policy - The organisation uses only specified, reputable employment agencies to source agency workers and always verifies the practices of any new agency it is using before accepting workers from that agency.
• Whistleblowing Policy - We encourage all our employees, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, Civica. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.
• Our values - Civica’s values of Knowledge, Integrity and Action makes clear to our employees the actions and behaviour expected of them when representing Civica. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.

Due Diligence

We undertake due diligence in relation to slavery and human trafficking when considering taking on new suppliers and review our existing suppliers on a periodic basis. Our due diligence and reviews include:

• Mapping the supply chain broadly to assess product and geographical risks of modern slavery and human trafficking
• Evaluating the modern slavery and human trafficking risks of each new supplier
• Conducting supplier audits or assessments which have a greater degree of focus on slavery and human trafficking where general risks are identified.
• When a supplier is deemed to be higher risk by country of origin and/or lack of suitable policy/processes, an investigation is raised and assessed by senior members of the Purchasing team which can result in the vendor being inactivated.
• Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Action Taken to Address Modern Slavery

Due to the nature of the supply chain, Modern Slavery risks are inherently higher in the hardware and peripheral item category, as the production process relies on factory labour.

Additional steps to manage the risk include sourcing goods from recognisable brands and reputable resellers, with evidenced processes and policies in place, along with products and suppliers that are assessed based on the country of origin. Countries and regions are assessed for risk based on the

Global Slavery Index, taking into consideration the latest updates from The Department for International Trade.

Awareness-raising Programme

The organisation has raised awareness of modern slavery issues by circulating information to employees.

The information explained to relevant employees:

• The principles of the Modern Slavery Act 2018 (Australia) and Modern Slavery Act 2015 (United Kingdom) and how they apply to Civica;
• How employers can identify and prevent slavery and human trafficking;
• What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
• What external help is available, for example through the Modern Slavery Helpline.

We are currently improving our colleague mandatory training and planning to strengthen knowledge through these activities.

April 2025 Update

Across the Civica Group, we continue to ensure that the working conditions for all our employees exceed statutory requirements in all the markets we operate in, and we conduct regular reviews against market standards. With 5000 employees globally, we continue to be an employer of choice across all our regions.

We continued to adapt our employee programmes and training to meet the needs of blended working; with a successful mix of virtual and face-to-face training as people began returning to our hubs.

In March 2024 we introduced a quarterly feedback system to capture employee feedback, which informs our ongoing efforts to enhance engagement and well-being.

We continue to support our people via our global network of Mental Health Champions, accredited through Mental Health England and St John Ambulance Australia.

We recognise that work is crucial to a person’s dignity, well-being and development and we are committed to the creation of jobs and working conditions in which people can work in freedom, safety, and dignity at a global level. We expect the same from all contractors, suppliers, and other business partners across our global supply chain. We are committed to identifying and assessing any potential risks and eliminating the possibility of modern slavery and human trafficking occurring in our business.

During 2024, we did not identify any high risk modern slavery concerns.

This statement is made pursuant to legislative requirements in each of the regions in which Civica operates and constitutes Civica’s slavery and human trafficking statement for the financial year ended 30 September 2024.

• Section 13(1) of the Modern Slavery Act 2018 (Australia)
• Section 54(1) of the Modern Slavery Act 2015 (United Kingdom)