Modern Slavery Act statement

1. Our business and structure

Ubique Group Limited is a private company registered in England and Wales, company number 12348871, with its registered office at 71-75 Shelton Street, London WC2H 9JQ. It is the parent of a group of subsidiaries that hold employment entities in 40 countries. Together the group provides employer of record, contractor management, global payroll, PEO and VEO services to about 1,200 client companies, employing team members in 160 countries and paying contractors in 200.

At 31 December 2025 the group had approximately 42 direct employees, all employed remotely, in 18 countries. Every Ubique employee is employed under a written contract that meets or exceeds local law, through the same entities and partners we use for clients. Our annual turnover exceeds the £36 million threshold at which this statement is required.

Our business is unusual in one respect that matters for this statement: we are the legal employer of many thousands of people who do their day-to-day work for someone else. We take the view that every one of those people is within the scope of our responsibility under the Act, whether they are employed by a Ubique entity or by one of our local partners on our behalf.

2. Our supply chain

Ubique's supply chain is small in number but significant in nature. It consists of:

1. Local employment partners. In the 120 countries where Ubique does not run its own entity, a vetted local partner is the legal employer of team members on our behalf. These partners are our most important suppliers and the area of highest potential risk, because they hold the employment relationship, run payroll and in some cases arrange accommodation or work permits.
2. Benefits brokers and insurers in about 60 countries, who provide health, pension and life cover to the people we employ.
3. Immigration partners in about 30 countries, who handle visa applications. Recruitment and immigration intermediaries are a recognised risk area for debt bondage and fee-charging, and we treat them accordingly.
4. Technology and professional services suppliers: cloud hosting, software, payment providers, auditors, law firms and the logistics providers who ship IT equipment to team members.
5. Clients. Although clients are customers rather than suppliers, they direct the daily work of the people we employ. Our client terms require them to comply with local employment law and our policies on working time, treatment and safety.

3. Our policies

The following policies, all reviewed in 2025, support our commitment:

• Modern Slavery and Human Trafficking Policy, applying to all employees, partners and suppliers, with a zero-tolerance position and a duty to report concerns.
• Partner Code of Conduct, which every local employment partner, broker and immigration partner must sign. It prohibits forced labour, child labour, recruitment fees charged to the individual, retention of identity documents, and wage deductions not permitted by law, and it requires written contracts in a language the individual understands.
• Client Terms of Service, which allow Ubique to refuse instructions that would breach local law or our treatment standards, and to end a client relationship where we find mistreatment.
• Whistleblowing Policy, with a confidential channel open to Ubique employees, team members employed through Ubique, contractors and partner staff, available in the 12 languages our platform supports.
• Recruitment Policy, under which Ubique never charges a fee to any individual for employment, and requires the same of partners and immigration intermediaries.

4. Due diligence

Before we work with a local employment partner, broker or immigration partner, we carry out a vetting process led by our Head of Legal. It includes verification of licences and operating history, review of audited financial statements, reference calls with existing clients, a security and data protection questionnaire, a sanctions and adverse media check, and a modern slavery questionnaire covering recruitment practices, fee arrangements, document handling, wage payment methods and subcontracting. Partners must confirm that no individual is charged a recruitment fee and that identity documents are never retained.

In 2025 we onboarded 9 new local partners and declined 4 applicants, 2 of them on grounds related to recruitment fee practices or incomplete answers to the modern slavery questionnaire. We ended one existing partner relationship after an audit found wage payments routed through an unlicensed intermediary; the affected team members were transferred to a new partner with no loss of pay.

We assess countries using a risk rating that combines the Global Slavery Index, ILO indicators and our own experience. Partners in higher-risk countries are audited more intensively and their team members are surveyed more often.

5. Partner audits

Every local employment partner is audited four times a year. Each quarterly audit includes a reconciliation of a sample of payslips against the amounts the client funded and the amounts received by the team member, so that unauthorised deductions are visible; a check of statutory filings against the local calendar; and a direct, anonymous survey of the team members the partner employs, which asks specifically about recruitment fees, document retention, freedom to resign and whether pay matched the payslip.

In 2025 we completed 468 partner audits. 14 resulted in a corrective action plan, most commonly for late statutory filings or payslip formatting. Two surfaced concerns relevant to this statement: one case of a partner holding a team member's passport "for safekeeping", resolved within 48 hours with the document returned and the practice prohibited in writing; and the intermediary case described above. No case of forced labour or trafficking was identified.

6. Training

All Ubique employees complete modern slavery awareness training at onboarding and annually. In 2025, 100% of employees completed it. Employees in Legal, Partnerships, Payroll and Customer, who are most likely to see warning signs, complete an extended module on indicators of forced labour and debt bondage, how to respond to a disclosure, and how to escalate. 71 employees completed the extended module in 2025.

Partner onboarding includes a session on our Partner Code of Conduct and the modern slavery questionnaire. From 2026, every partner's named HR contact will be required to complete our awareness training as a condition of the relationship.

7. Measuring effectiveness

We track and report to the board annually: the proportion of partners audited on schedule (100% in 2025), the number of modern slavery indicators raised through audits, surveys and the whistleblowing channel (2 in 2025, both resolved), the time taken to resolve them (both within 10 business days), training completion rates, and the number of partner applicants declined on modern slavery grounds. These indicators are reviewed by the Head of Legal quarterly and by the board annually.

8. Plans for 2026

• Extend the partner audit survey to contractors paid through the platform in higher-risk countries, who are outside the employment relationship but within our reach.
• Require immigration partners to provide a written fee breakdown to every applicant before any work begins, confirmed in the platform.
• Make awareness training mandatory for partner HR contacts, as described above.
• Publish the list of countries we rate as higher risk, and the additional measures that apply, to clients in the dashboard.

9. Approval

This statement was approved by the board of directors of Ubique Group Limited on 24 March 2026 and is signed on its behalf by:

Hanna Lindqvist
Chief Executive Officer and Director
Ubique Group Limited
24 March 2026

Statements for previous financial years are available on request from hello@ubiquehq.co.uk. Concerns about slavery or trafficking connected to Ubique, a partner or a client can be reported confidentially to the same address or through the whistleblowing channel in the platform.