1 INTRODUCTION FROM THE CHIEF EXECUTIVE OFFICER

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another, in order to exploit them for personal or commercial gain.

 Our commitments:

To act ethically in accordance with the Ethical Trading Initiative and with integrity in all our business dealings and relationships, and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

To ensure transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers. will hold their own suppliers to the same standards.

To improve our practices to combat slavery and human trafficking. Kelly Deli Company Limited, as the holding group of the 'KellyDeli Group', is taking steps to ensure compliance with legislation relating to Anti- Slavery and Human trafficking, as well as doing its utmost to go above and beyond these requirements. Kelly Deli has taken these positive actions to combat these unfortunate trends and is committed to continuously improving these processes.

2  OUR STRUCTURE AND SUPPLY CHAINS

We are a global food retail and restaurant group. We are the parent group of the Kelly Deli subsidiaries in the following countries: France, Belgium, Spain, Italy, the United Kingdom, Germany, the Netherlands, Sweden, Denmark, Finland, Portugal, and Mexico ("Kelly Deli Company Ltd"). As of December 2024, the Group had 322 employees across the world.

2.1 OUR BUSINESS

Kelly Deli is an innovative food group committed to bringing the best of Asia to the world, through Asian- inspired brands and over 1,000 kiosks across Europe, the United Kingdom and Mexico. KellyDeli is a franchisor supporting a network of independent kiosk owners preparing and offering for sale Asian inspired food in supermarkets, hypermarkets and similar. Kelly Deli also has a presence in UAE via a franchisor agreement.

2.2 OUR SUPPLY CHAINS

Our supply chains include over 65 suppliers throughout Europe who supply products to each of our kiosks. These suppliers range from large scale cross-country suppliers to local small-scale suppliers.

3 OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

Our Modern Slavery Policy and the modern slavery clause in all our supplier contracts reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and promoting effective systems and controls.

Other policies include equality, diversity & inclusion, whistleblowing, harassment & bullying, code of conduct, anti-fraud and bribery.

In 2021 KellyDeli included as part of their suppliers' contracts several ethical obligations. All contracts are reviewed to ensure consistent ethical obligations are met.

In 2023, we highlighted our policies monthly via our internal communication platform, starting with Whistleblowing in August and a reminder of the free phone line and website to report any potential wrongdoing.

4 DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

As part of our initiative to identify and mitigate risk we have a free and independent whistleblowing line available 24/7 and 365 days, to all employees. The aim is to:

●     Identify and assess potential risk areas in our business.

●     Mitigate the risk of slavery and human trafficking occurring in our business.

●     Monitor potential risk areas in our business; and

●     Protect whistleblowers.

Where an issue is spotted at internal, suppliers', or partners' level, a corrective action plan is requested. If the action plan does not sufficiently address the issue, the contract will be at risk of termination.

Across our network of franchisees, our partners and their employees have access to "contact Mike", which is a direct line to reach out to our Chief HR Officer at KellyDeli to report any issue or problem they might be experiencing that cannot be resolved by the local KellyDeli team. In 2024, a reminder of this procedure was shared with all partners via our internal training platform.

In 2024, in the UK and France, a poster to further enforce the "contact Mike" procedure has been displayed in each kiosk.

We also introduced in 2024 a red flag check of our employee and partner records, which will be carried out on an annual basis, that aims at identifying any potential early warning signs. In 2024, the red flag check was performed in France, Belgium, the Netherlands, Germany, the United Kingdom, Spain, and Portugal.

5 RISK ASSESSMENT

KellyDeli is committed to respecting and protecting the human rights of all those who are in contact with its operations, including employees, partners, and supply chain workers. KellyDeli supports transparency, to find and resolve problems; to regularly review business practices; and to collaborate to protect the rights of workers, particularly those who are most vulnerable and exposed to abuses such as modern slavery.

A detailed risk assessment is key to help focus on the areas where we face the greatest risk. The introduction of policies and training for our people helps identify any signs of modern slavery and empowers them to act accordingly.

In 2022 two Managers from KellyDeli were trained to use Radar - a risk Management tool allowing us to better scope and assess potential risks across our operations and supply chain. We conducted a risk assessment of our supply chain by product and country of operations and were able to flag higher risk suppliers (prawn farming / fisheries) and from a location perspective, two countries (Mexico and UAE) of operations being flagged as medium risks.

In 2024, we reassessed our modern slavery risk among 65 suppliers. We instructed an external specialised consultancy firm to conduct due diligence on modern slavery risk and mitigation actions in place among our suppliers. This project allowed us to better understand the risk in our company and plan improvement workstreams.

6 MEASURING EFFECTIVENESS

In 2020, we strengthened and developed the effectiveness of our risk management processes. KellyDeli appointed a General Counsel reporting directly to the CEO and a head of employee relations to strengthen its commitment further. Several new policies were implemented in 2020, spanning equality, diversity, and inclusion, whistleblowing, harassment & bullying, code of conduct, and Modern Slavery policy.

 
Kelly Deli has an ethical task force, dedicated to plan, assess, and continuously promote best practices related to human rights, ethics, and equality. The role of the task force is to actively manage any potential risk linked with human rights breaches and to ensure continuous improvement in this arena.

A free and completely independent whistleblowing helpline is available to all employees. The whistleblowing hotline and online reporting tool (Safecall website) allow employees to speak up and report their concerns anonymously to the highest levels of management. It is available to all Kelly Deli employees, 24 hours a day and 365 days per year, in 49 languages (via online service).

In 2021, KellyDeli joined a global platform allowing to better assess social and environmental risks by countries of operations and industries. The system enabled KellyDeli to access their suppliers social and environmental audits and assess their progress against a set of internationally recognised standards.

In 2024, we reviewed the "contact Mike" procedure and reinforced the importance of raising any concerns partners and their employees may have through an email sent to our franchisee network in the UK, Spain, Portugal, Italy, France, Belgium, and the Netherlands.

7 TRAINING

In 2021, we moved all employee and partners' training programs to an online platform. Training for employees includes human rights, responsible recruitment, diversity and inclusion as well as modern slavery. Kelly Deli's values are fully integrated in the policies and partners' practices through their onboarding programme and online training suite. The group updates and creates new modules regularly to make sure partners are armed with a strong knowledge base in all areas relating to fundamental values we believe in.

In 2023, 80% of all employees completed the anti-modern slavery training, and 81% completed the diversity and inclusion e-learning modules.

In 2024, a tailored modern slavery prevention training was created for partners with a mandatory annual completion. The completion rate for this training was 86%.

We are committed to respecting and protecting human rights of all who come into contact with our operations, including employees, partners and supply chain workers. We accept our responsibility to support transparency, to find and resolve problems; to regularly review our business practices; and to collaborate with others to protect the rights of workers, particularly those who are most vulnerable to abuses such as modern slavery.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes KellyDeli Company's slavery and human trafficking statement for the financial year ending December 2024. This statement will be presented to the board on 04 June 2025.