Modern Slavery and Human Trafficking Statement

UG UAE. Financial Year 2026

1. Introduction

This statement is made by UG UAE ("UG UAE", "the Group", or "we") pursuant to section 54(1) of the United Kingdom Modern Slavery Act 2015 (as amended in 2025) and constitutes our slavery and human trafficking statement for the financial year ending in FY 2026. It sets out the steps UG UAE has taken during the reporting period to identify, prevent, and mitigate the risk of modern slavery, servitude, forced or compulsory labour, and human trafficking (collectively, "modern slavery") occurring within our own operations and our supply chain.

UG UAE does not tolerate modern slavery in any form. We have implemented governance, contractual, and operational controls designed to ensure that the people who work for us, with us, and on our behalf are recruited fairly, employed lawfully, and treated with dignity. We require the same standards of every entity in our supply chain.

This statement has been reviewed and approved by the Board of Directors of UG UAE and will be refreshed annually.

2. Organisation Structure and Supply Chain

UG UAE is an international defence and security firm organised across four operating divisions:

• Field Operations. protective operations, deployments, and training services delivered to government, institutional, and private clients.
• Defence Technology. design, integration, and supply of counter-uncrewed-aerial-system (counter-UAS) capabilities, drones, and associated hardware.
• UG Cortex. intelligence, analytics, and decision-support software for security, geopolitical, and operational use cases.
• Intelligence Advisory and Investigations. discreet intelligence, due diligence, and investigative services.

The Group operates internationally, supporting sovereigns, ultra-high-net-worth principals, owners and operators of critical infrastructure, and intergovernmental and non-governmental organisations.

Our supply chain reflects the breadth of these divisions and includes, without limitation: technology vendors (cloud, software, communications, and cyber); equipment suppliers (electro-optical, electronic, mechanical, mobility, and personal protective equipment); professional services (legal, accounting, insurance, recruitment, language, and translation); security and physical infrastructure providers (facilities, transport, logistics, and travel services); and locally engaged personnel and subcontractors retained in support of specific deployments.

3. Policies Relating to Modern Slavery

UG UAE maintains a documented framework of policies that govern conduct across the Group and its supply chain. The following are the principal instruments relevant to modern slavery:

• UG UAE Code of Ethics (/company/ethics), sets the ethical standards required of all directors, officers, employees, contractors, and agents, including express prohibitions on forced labour, child labour, and human trafficking.
• Supplier Code of Conduct (/legal/supplier-code), extends UG UAE's ethical standards to suppliers, subcontractors, and business partners, and sets out mandatory minimum standards on labour rights, working conditions, recruitment practices, and freedom of association.
• Recruitment Standards. require lawful right-to-work verification, prohibit the charging of recruitment fees to workers, prohibit the retention of identity documents, and require written contracts of employment in a language the worker understands.
• Whistleblowing Policy. provides confidential reporting channels for employees, contractors, suppliers, and third parties to raise concerns about suspected modern slavery or other ethical breaches without fear of retaliation.

These policies are reviewed at least annually and updated to reflect changes in law, regulatory guidance, and operating risk.

4. Due Diligence Processes

UG UAE applies risk-based due diligence to its workforce and supply chain. Our processes include:

• Pre-engagement supplier vetting. New suppliers are screened for modern slavery risk before contracting. Screening covers ownership, jurisdiction of incorporation, nature of activity, sanctions and adverse-media exposure, and labour-rights track record.
• Contractual flow-down. Standard contracts require suppliers to comply with the Supplier Code of Conduct, to flow equivalent obligations to their own sub-tier suppliers, and to permit audit on reasonable notice.
• Ongoing monitoring. We re-screen suppliers periodically and on trigger events (change of control, adverse media, jurisdictional escalation).
• Geographic-risk weighting. Suppliers and engagements operating in jurisdictions identified as elevated risk by recognised indices, including the Global Slavery Index and applicable government advisories, are subject to enhanced due diligence.
• Sub-tier transparency. For higher-risk engagements, we require suppliers to disclose material sub-tier suppliers and the locations at which work is performed.
• Remediation. Where credible indicators of modern slavery are identified, we engage with the supplier to require corrective action, escalate to termination where necessary, and report to relevant authorities where the law or our policies require.

5. Risk Assessment and Management

UG UAE has assessed modern slavery risk across the following categorical risk areas:

• High-risk geographies for forced labour. Field Operations and Intelligence Advisory engagements may take place in jurisdictions with elevated forced-labour risk. We mitigate through enhanced supplier due diligence, direct employment of personnel where feasible, and contractual prohibitions on subcontracting without prior written consent.
• Contractor and subcontractor chains. Multi-tier subcontracting can obscure labour conditions. We mitigate through flow-down clauses, sub-tier disclosure requirements, and audit rights.
• Recruitment-fee practices. Worker-paid recruitment fees are a recognised indicator of debt bondage. We prohibit the charging of recruitment fees to workers across the Group and our supply chain and require labour providers to certify compliance.
• Equipment supply chains. Electronic components, raw materials, and consumer-grade hardware can carry forced-labour risk in upstream tiers. We engage with technology and equipment suppliers on their own modern slavery programmes and prefer suppliers that publish a section 54 statement or equivalent.

Risk assessment is reviewed at least annually and on material change to operations or supply chain composition.

6. Training

UG UAE has implemented mandatory annual ethics training for all personnel. The training covers the indicators of modern slavery and human trafficking, the obligations of personnel under the Code of Ethics, and the channels for reporting concerns. Personnel in procurement, supplier management, and human resources functions receive additional role-specific training covering supplier due diligence, contract flow-down, and red-flag escalation.

Training completion is tracked and reported to the Board.

7. Effectiveness Measurement

UG UAE measures the effectiveness of its modern slavery programme against the following control-based indicators:

• Supplier coverage. All active in-scope suppliers are contractually bound by the Supplier Code of Conduct as a condition of engagement, with onboarding gated on acceptance of those terms.
• Workforce training. Annual ethics training covering modern slavery indicators is mandatory for all in-scope personnel, and completion is a tracked condition of continued engagement.
• Role-specific training. Procurement and human resources personnel complete additional role-specific training on supplier due diligence, contract flow-down, and red-flag escalation as a condition of holding those responsibilities.
• Reporting channels. Concerns raised through the whistleblowing channel relating to modern slavery are logged, triaged, and addressed within defined target timelines, with outcomes reported to the Board.
• Supplier assurance. Supplier audits and assessments are conducted on a risk-prioritised basis, and any corrective-action plans are opened, tracked to closure, and reviewed by management.
• Enforcement. Supplier engagements are terminated where credible modern slavery or related breaches are confirmed and cannot be satisfactorily remediated.

These indicators are reported to the Board at least annually and are used to direct improvements to the programme in subsequent reporting periods.

8. Approval and Signature

This statement was approved by the Board of Directors of UG UAE LLC on 2026-06-09 and is signed on its behalf.

Approved by the Board of UG UAE LLC For and on behalf of the Board of Directors, UG UAE LLC Date: 2026-06-09