Modern slavery statement

 21 May 2026

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015.

Enhesa is a trusted partner to drive the transformation of compliance and sustainability. Enhesa brings together best-in-class solutions as the leading provider of regulatory and sustainability intelligence worldwide. An integrated global business on a mission to make a difference – and to empower you to make our world a more sustainable place.

Enhesa Group N.V. (hereinafter, “Enhesa”) respects and promotes human rights, and through its business and operations, seeks to actively contribute to a more prosperous, equitable and fair society.

This statement covers the activities of the whole Enhesa, for the financial year running from January 2025 to December 2025.

Our organisation’s structure, our business, and our supply chain

Enhesa Group N.V. comprises Enhesa N.V., which is the parent company of Enhesa Inc. in the US, Enhesa Kabushiki Kaisha in Japan, Enhesa (Shanghai) co. (China) Ltd., and CW Research Limited in England.

Enhesa Inc. has as subsidiaries Scivera LLC, Timberlake Ventures Inc., and Reg Scan LLC. Enhesa, N.V. has an office in Belgium and a branch in Portugal. Enhesa Inc. has offices in the US and one in Canada.

Our core activities are providing intelligence to multinationals and enabling them to be compliant no matter how simple or complex their operations. We enable them with intelligence for their operations, products, processes, and chemicals management across the globe.

Enhesa’s solutions include EHS intelligence, Product intelligence, Sustainable Chemistry, and Corporate Sustainability. These help companies address regulatory and sustainability challenges in a global landscape. Regscan by Enhesa provides a vast regulatory library for compliance programs for mid-market companies in the US.

Our expertise means that we can guide organisations through the ever-changing landscape of operational compliance, product regulations, and chemical sustainability so you can ensure the safety of your employees, consumers, communities, and the environment.

In this context, Enhesa’s supply chain is integrated by service suppliers and some goods suppliers. Specially subcontractors in the case of service suppliers.

Our journey and our policies

Enhesa has the following policies related to respecting Human Rights and to prevent any modern slavery issues. Modern slavery understood as the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation:

• Human Rights Policy: applicable to all Enhesa Group and through its business operations. The policy is based on international instruments, such as the Guiding Principles for Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework (UN) and the Forced Labor Convention (International Labor Organization – ILO).
• Sustainability and ESG Policy: which outlines our commitment to the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct.
• Sustainable Procurement Policy: which enables buyers within the Enhesa Group to select suppliers which are aligned with our values and commitments such as respecting human rights, good labour practices, and not tolerating any form of modern slavery. This policy also provides the basis for buyers to conduct reasonable due diligence.
• Recruitment Policy: which respects human rights of candidates and prohibits recruiting any person below the legal age to work.
• Global Whistleblowing Procedure: which allows any employee and stakeholder of Enhesa group to raise concerns, such as human rights violations. This procedure is on our public website and accessible to any worker in the supply chain.
• Supplier and Business Partner Code of Conduct: which requires among others for Business partners and suppliers to respect all internationally recognised human rights as set out in the Universal Declaration of Human Rights. They shall not use, promote or allow forced labour in any form, including human trafficking or modern slavery practices and they shall implement due diligence procedures to help identify, prevent and mitigate any instances of modern slavery within their value chain.

Knowing our value chain and the most vulnerable parts presenting higher risks

Enhesa’s supply chain includes service providers and goods suppliers.

We understand that there are sectors and countries with a higher risk of exposure than those where we operate — Belgium, Canada, China, Japan, Portugal, UK, and US. Even if we operate in countries and a sector with lower risk, according to the Global Slavery Index (https://www.walkfree.org/global-slavery-index/), we acknowledge we also have a part to play.

According to the Human Rights Guidance tool for investment, the services sector comprising professional services has a wide variety of risks. The main risks can include low wages and long hours; substantial use of migrant workers; trafficking of workers, especially women and children, who are then forced to work.

As part of our actions, we make use of various sources to understand the risks and be able to identify, prevent, mitigate, and provide remedy where possible.

Enhesa has developed the Sustainable Procurement Practice Policy which enables Enhesa to conduct due diligence on (tier 1) suppliers by searching in the Database of specific instances from the Organisation for Economic Co-operation and Development (OECD) for any pending instance for failing to conduct responsible business in accordance with the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct by the supplier. We understand this is the beginning of a continuous improvement. We aim to have more visibility on further down our supply chain beyond Tier 1 in the future.

It is important to acknowledge that the due diligence has to be proportional to the business, operational context, and sector and that is Enhesa’s approach as explained in this section.

Our performance indicators and their effectiveness

There are six actions conducted for year 2025 and their key performance indicators:

1. Keeping track of incidents or complaints of modern slavery and treating the complaints (KPI: number of incidents or complaints of modern slavery and treatment of these)
2. Keeping track of the number of new vendors listed with an instance in the Database of specific instances of the OECD (KPI: number of vendors listed with an instance and engaging with them if listed)
3. Conducting a vendor analysis for Y2025 to understand our Tier 1 suppliers and whether they are in an area of modern slavery prevalence (KPI: completing vendor analysis for Y2025)
4. Strengthen our due diligence by developing a mechanism to understand which vendors have controls and measures in place to identify, prevent and remediate cases of modern slavery and forced labor in their own supply chains
5. 50% of our new suppliers agreeing to our Suppliers and Business Partners Code of Conduct (baseline number of new suppliers based on 2024 data which is 50 suppliers)
6. Providing training on Modern Slavery and Forced Labor to all Enhesa staff

Keeping track of incidents or complaints of modern slavery

With the issuance of the Whistleblowing procedure Enhesa has put at disposal of any person the contact numbers to report in case of serious concern related to human rights violations (including modern slavery).

Conducting a vendor analysis for Y2025

We have conducted a vendor analysis for the year 2025. We looked at the transactions and amounts in 2025 per vendor, and we used the vendor location to determine the prevalence based on the available Global Slavery Index. We have also based our analysis taking into consideration the vendor category, since there are certain products or service categories that are considered as high risk.

The analysis methodology consisted in reconciling three data sources including the purchased goods and services, and the responses to the Sustainable Procurement Form. Enhesa has 663 vendors.

The results show that:

Enhesa’s suppliers are predominantly located in countries with low prevalence of modern slavery.

• Very few transactions occurred with countries with high modern slavery prevalence rate. The transactions in countries with high prevalence were analysed further and the transaction is related to individuals lending their professional services to Enhesa or to a subscription to the official journal. This is expected due to the nature of our activities; we use professional services and we also contract subscriptions to official journals in order to develop the content for our customers.
• One of the vendor categories at risk of modern slavery in their supply chains is electronics, according to Walk Free; however, Enhesa has a very low risk exposure considering the amount spent on this category is extremely low compared to the total spend and location of vendors. Additionally, we have looked at the recruitment vendor category which could also pose a risk. Based on the location, the recruitment vendors are not located in a country with high prevalence.
• 14% of the vendors have completed the Sustainable Procurement Form. Representing 25.7% of the total spend in purchased goods and services by Enhesa. The remaining 74.3% of spend is undocumented through this channel and the reason is that the form was launched in 2023 for new vendors and it has not been launched to capture existing vendors. Regarding existing vendors, in 2025, Enhesa engaged with our top 23 vendors (based on 2024 spent) so that they can share an ESG or Sustainability independent performance assessment, as a result we have 39% of vendors who shared their ESG or sustainability assessment, 30% do not have an independent performance assessment but they have shared sustainability reports or other relevant information and mentioned they were willing to carry an assessment, 9% of vendors were no longer working with Enhesa, other 9% didn’t respond back, and 13% Enhesa was not able to reach out the right person or are a small or very small company and Enhesa decided not to reach out.

Keeping track of vendors listed with an instance in the OECD Database

The Sustainable Procurement Policy and its mechanism to conduct reasonable and proportionate due diligence has allowed us to check new vendors (new vendors are those registered within our internal system from 1 January to 31 December 2025) to see if they are subject to a specific instance in the Database of specific instances from the Organisation for Economic Co-operation and Development (OECD).

During the reference period we have checked 103 new vendors and none of them has an instance in the mentioned database. The reason for tracking this is to identify vendors with a specific instance (a non-observance of the OECD Guidelines which includes respect to human rights) and determine the next steps to have meaningful engagement with vendors in such cases.

Note: New vendor refers to vendors onboarded in 2025 who have completed the sustainable procurement form.

50% of new suppliers agreeing to our Code of Conduct

Based on 2024 data, we had 50 new vendors from which only 10% acknowledged Enhesa’s Supplier and Business Partner Code of Conduct. This is due to the introduction of the acknowledgement in Q4 2024. Therefore, Enhesa set as a target for 2025 to get 50% of new vendors to acknowledge our Supplier and Business Partner Code of Conduct (our 2024 baseline is 10%).

Following enhancements to our vendor onboarding and contracting procedures, acknowledgement of the Supplier and Business Partner Code of Conduct has been systematically embedded.

The Supplier and Business Partner Code of Conduct sets out our expectations on ethical conduct, labour standards, and human rights, including the prohibition of forced and compulsory labour.

(1) New vendor refers to vendors onboarded in 2025 who have completed the sustainable procurement form. In 2025, these were 103.

Strengthening our due diligence

Enhesa enhanced its due diligence processes during the reporting period by enhancing its sustainable procurement questionnaire (form). The updated questionnaire requires vendors to disclose what are the policies and measures in place to identify, prevent and remediate risks related to forced labor and modern slavery within their own operations and where relevant, their supply chains. This enhancement supports Enhesa’s approach to responsible sourcing and reinforces expectations for suppliers to uphold internationally recognised human rights standards.

Providing training on Modern Slavery and Forced Labor to all Enhesa staff

In 2025, Enhesa assigned a mandatory training on modern slavery and forced labor to all staff. The training focuses on what modern slavery and forced labor is; how to identify victims of forced labor and modern slavery; and Enhesa’s approach to prevent, identify, and remediate any instance related to modern slavery and forced labor.