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Modern Slavery and Human Trafficking Statement

For financial year ending 31 May 2025

Senior Management Statement

Open GI is committed to preventing modern slavery and human trafficking in all areas of our business and supply chain and has a zero-tolerance approach to any form of slavery, servitude, forced or compulsory labour, and human trafficking.

We commit to uphold good governance and business practices and to take a zero-tolerance approach to any exploitation of individuals, including those offences covered by the Modern Slavery Act 2015 within our business and supply chain, and impose the same high standards on our suppliers. We strive to do our part in opposing modern slavery and human trafficking in any form, and we will take measures necessary to prevent it.

This statement is in accordance with the Modern Slavery Act 2015, particularly Section 54 (Transparency in Supply Chains), which requires commercial organisations with a turnover greater than £36 million to publish an annual Modern Slavery Statement.

Structure of the Organisation

Open GI is a recognised as one of the leading technology partners to the general insurance industry in the UK and Irish markets, with a strong history of innovation. Open GI’s primary investor is the Ares Management Group, which is a global alternative investments firm.

The Open GI group of companies includes entities of Open GI London, Open GI Ireland, Transactor Global Solutions Limited (TGSL), Powerplace, and Machine Learning Programs (MLP). Most employees are employed under Open GI Limited, and those entities listed may be trading names. We have offices in Worcester, UK (head office), Milton Keynes, Winchester, Poland, and North Macedonia. Open GI employs approximately 470 people across these locations.

To find out more about the nature of our business, please visit our website at opengi.co.uk.

Policies

We are committed to combating modern slavery and human trafficking, and this commitment includes a robust modern slavery policy. We also have other policies that promote a transparent, inclusive, fair, and equitable workplace.

  • Anti-harassment policy
  • Code of conduct
  • Diversity, equity and inclusion policy
  • Equal opportunities policy
  • Speak up policy / Whistleblowing policy

These policies have been developed internally with input from multiple areas and all policies receive senior management approval as appropriate. Policies are made available to all employees via the policy library on its corporate intranet and are supported by the HR team for notification of material changes.

We hold our suppliers to the same high standards and ensure they are aware of our policies.

Due Diligence

To effectively serve our clients and manage our operational infrastructure, we partner with a diverse range of suppliers and businesses. Examples of these are facility management suppliers such as cleaners, gardeners, utility trades, etc. through to partners who assist us with the provision of our services. Examples of these are data centres, software providers, enrichment services, etc.

As part of our efforts to monitor and reduce the risk of slavery and human trafficking, we have implemented a due diligence process which is underpinned by our Vendor Risk Management Policy. Our Compliance team oversees the due diligence programme and selects appropriate targets for assessment using a risk-based criteria. All outcomes are recorded, and we will work with our suppliers should any concerns be noted.

Risk Management

Open GI regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain through the above-mentioned due diligence process. We also track its effectiveness via our group register, on which it currently has a low residual risk.

High risk sectors would typically be recognised by short term or seasonal workers, agriculture, retail manufacturing, hospitality, car washing, etc. As a software development and technology solutions provider, we do not consider that we operate in a high-risk sector or locations. However, through our risk management and due diligence processes, we always ensure that we maintain a robust programme that ensures its continual effectiveness.

Training

We invest in educating our employees to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programmes and our written policies, employees are encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy. This can be directly through their management chain, or anonymously through our Speak-Up process and its supporting policy.

Relevant training courses that we have provided to all employees over the past year are:

  • Modern Slavery
  • Harassment in the Workplace
  • Equality and Diversity in the Workplace
  • Bribery Prevention
  • Unconscious Bias
  • Whistleblowing

All the above are annual mandatory awareness courses. These are actively tracked and managed through our People Services team.

Further Actions and Sign-Off

Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps to tackle slavery and human trafficking:

  • Continue to evolve and strengthen our supplier due diligence process
  • Complete the rollout of our Supplier Code of Conduct which is currently in draft
  • Continue to evaluate the suitability of our awareness training material
  • Maintain regulatory oversight of any changes to the Modern Slavery Act 2015 or related guidance

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Open GI’s slavery and human trafficking statement covering the financial year 1 June 2024 through to 31 May 2025.

This statement was approved by the executive board on 11 September 2025.

‍

Signed: Simon Badley

Group Chief Executive Officer

Open GI

‍

Previous statements are available upon request from compliance@opengi.co.uk

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