MODERN SLAVERY, HUMAN TRAFFICKING, AND CHILD LABOUR STATEMENT

Covering Financial Year to 31 December 2025

Modern slavery, human trafficking and child labour are abuses that undermine human rights, perpetuate inequality and erode trust in business. This statement outlines the steps that Serverfarm Global Holdings Ltd. (“we” or “us”) takes to prevent, detect and respond to risks of modern slavery, human trafficking and child labour in our operations and supply chains. It is published in accordance with the Modern Slavery Act 2015 of the United Kingdom.

Our Structure and Operations

Serverfarm Global Holdings Ltd. is part of the group of affiliated international companies that form Serverfarm, which has been designing, building and operating data centres internationally for over 25 years. We have data centres in the metropolitan areas of both London and Amsterdam, and our team comprises over 40 employees and consultants. Our work includes site acquisition, facility design, construction and fitout, commissioning, operations and maintenance, and capacity expansion to provide critical power, cooling, IT infrastructure, security and environmental management to cloud providers and enterprises with high performance and missioncritical uptime requirements.

Our Supply Chain

Our supply chain consists of a combination of global and local suppliers, including global equipment manufacturers providing equipment for critical power, cooling and IT; engineering and construction contractors supporting facility development, fit-out and modernization; local service providers including security personnel, janitorial services and waste management and utility companies; and professional consultants and vendors assisting with business strategy, operations, accounting, development and people processes. We have identified a higher risk for modern slavery and human trafficking associated with certain geographic locations outside developed economies, including in connection with manufacturing imported components and other economic activities that could involve migrant or contract workers.

Our Policies

We are committed to preventing modern slavery and human trafficking in our business activities and regularly review our policies to maintain alignment with industry best practices and evolving legislation. Our Modern Slavery Policy sets out our zero tolerance for slavery, forced labour, child labour or human trafficking and applies to all persons working for us or on our behalf, including our employees, consultants, contractors, suppliers and agents. Our code of conduct includes requirements on fair treatment, prohibition of child labour, freedom of association, the right to terminate employment, no confiscation of documents and no exploitative overtime. We communicate our policies and reinforce the importance of preventing modern slavery, human trafficking and child labour via our People platform and our Employee Handbook.

Risk Assessment and Management

Our Compliance, Procurement and People teams share responsibility for managing, assessing and monitoring risks in our operations and supply chain, and for reporting findings to the Sustainability Committee, a senior governance body, to ensure that modern slavery risks are identified, communicated, and mitigated. We conduct risk assessments when onboarding suppliers, and every year thereafter, to identify where there is potential for modern slavery. Risks are prioritised based on several factors, such as geography, sector, stage in supply chain, type of workers (migrant, contract, agency) and vulnerability (language, legal status, pay, skills). To date, we have identified no modern slavery, human trafficking or child labour in connection with our supplier engagements.

Supplier Contracting and Due Diligence

All new suppliers, contractors and service providers are required to review and sign contractual agreements that prohibit using forced or trafficked labour, or anyone held in servitude, whether adults or children, and require due diligence and inspections to ensure downstream contractors, suppliers and service providers adhere to the same standards. We reserve the right to audit compliance and terminate our relationship in the event of noncompliance. Suppliers are evaluated on a case-by-case basis, and we conduct enhanced due diligence, such as thirdparty verification, with highrisk suppliers. If we identify credible risks of modern slavery, human trafficking or child labour, then we will require the supplier put corrective action plans in place, and if we discover or reasonably suspect instances of modern slavery, human trafficking or child labour, we will terminate the relationship.

Employee Training

Our employees undergo modern slavery and human trafficking training via our People platform when employment commences and once per year thereafter. Our trainings include modules on identifying risk, understanding policies, roles and responsibilities and how to escalate concerns. We provide additional online training for our UK employees and consultants who are most likely to encounter risk, for example by ordering imported goods or dealing with construction contractors. Managers also receive guidance on spotting signs of labor exploitation and escalating concerns.

Reporting

We maintain multiple channels, including a whistleblowing hotline and anonymous reporting via the People mailbox, for employees, contractors or third parties to report concerns regarding modern slavery and human trafficking. Employees can also report concerns to their managers, our People team or the Legal team. Our People team maintains and observes procedures for investigating reports and remedying identified issues.

Monitoring

We are committed to transparency, continuous improvement and responsible business practices and to continuing to monitor, assess and improve our processes to eliminate modern slavery and human trafficking. We conduct audits to verify compliance with our policies. Each year, we set specific, measurable goals for the coming year to increase audit coverage and improve remediation mechanisms. To measure our progress and effectiveness, we track the annual completion rate of employee training on modern slavery awareness, the number of reported incidents of suspected slavery or trafficking within operations or supply chains (goal: zero), and audit findings and remediation actions for high-risk suppliers. We review our progress annually based on actual data to identify areas for improvement. Our employees and suppliers must cooperate with our audits and monitoring activities, and any employees or suppliers who do not do so, or who otherwise hinder any investigation, will face termination.

Board Approval

This statement was approved by the Board of Directors of Serverfarm Global Holdings Ltd. on October 23, 2025.

Jim Shanhan
Director, Serverfarm Global Holdings, Ltd.