Modern slavery statement

M.P. Evans Group PLC (“the Company” or “the Group”) takes its responsibilities to combat slavery and human trafficking seriously.

This is the Modern Slavery statement for 2025 of M.P. Evans Group PLC (“the Company” or “the Group) under section 54 of the UK Modern Slavery Act 2015. It provides information regarding the steps taken by the Group, to prevent slavery and human trafficking within its own organisation and that of its supply chain.

Corporate structure

The Company is the holding company of a Group with its subsidiaries operating oil-palm plantations in Indonesia. The Group’s Indonesian operations are subject to the standards and practices set by the Company as UK parent. The Group’s turnover (US$352.8m in 2024) derives almost entirely from its Indonesian plantations. In 2024, the Group harvested over 1.2 million tonnes of fresh fruit bunches from the estates it managed, and its six palm-oil mills produced 356,200 tonnes of crude palm oil and 78,000 tonnes of palm kernels. The Group has over 12,000 employees at its estates, including those involved in agricultural and mill work, as well as trained teaching staff and medical professionals employed in its schools and clinics, where these are provided on its estates. Almost all the Group’s workforce is Indonesian.

In addition, the Group works with contractors who are responsible for the delivery of other services required by the business, for example planting, construction and transportation. The Group also buys in supplies critical to its operations, including seedlings, machinery, spare parts, vehicles, tools, fertiliser and other products such as pesticides approved for agricultural use. It also purchases oil-palm fresh fruit bunches from third parties for processing in its palm-oil mills. All purchasing is managed or supervised by the Group’s dedicated procurement team.

The board’s role

The Group’s board acknowledges its responsibility to ensure that it has effective and appropriate measures in place to mitigate the risk of modern slavery and human trafficking occurring in its own organisation and in its supply chain. As part of good governance and stakeholder communication, it is committed to ensuring transparency around how it tackles modern slavery.

Risk identification

The Group’s board recognises that, due to the nature of its business, with a reliance on a large workforce deployed in remote locations, there is an elevated risk associated with modern slavery and human trafficking. Some of the products and services the Group relies on in its supply chain are also associated with higher risk of modern slavery. The board also understands the serious reputational and financial risks to the business if the Group is found to be associated with modern slavery or human trafficking either within its own operations or in its supply chain. The board takes these risks very seriously and has developed policies and due diligence processes to mitigate against them, which are described below. The board takes an active interest in the way management identifies and meets these risks.

Policies

The Group’s board has implemented specific policies as the basis of its framework for tackling modern slavery risk. The Group’s modern slavery and human trafficking policy (“MSA Policy”) was first issued in July 2017 and clearly sets out the Group’s zero-tolerance approach to modern slavery, how it can be recognised and how the Group expects its employees to respond if instances are suspected. In addition, the board implemented a whistleblower policy in 2018 which is supported by an independently run whistleblower hotline to enable anonymous reporting. In addition, the Group’s Sustainable and Ethical business policy sets out the Group’s commitment to the welfare and rights of its employees. The Group’s board has full oversight of these policies.

The Group’s Modern Slavery Act statement and all related policies and procedures are reviewed and approved by the Group’s board annually and published on the Group’s website. The review process is the responsibility of the chief financial officer.

What steps has the Group taken to tackle the risk of modern slavery and human trafficking?

The UK executive directors work closely with the Group head of risk in Indonesia to co-ordinate and develop strategies to mitigate against modern slavery risk. A multi-departmental modern slavery committee was established in 2024 comprising representatives from the Group’s business areas. This committee, chaired by the Group company secretary, meets at least three times a year for open discussions with the UK executives, as well as the president director in charge of operations and the Group head of risk. The committee has produced a risk-mapping document which identifies risks in relation to the key business areas, any mitigation strategies already undertaken, and those planned. This document has been helpful to give senior management a deeper understanding, as well as oversight, of the processes in place or being developed, including any due-diligence challenges faced. The collaborative approach of the committee ensures that departmental goals and efforts are aligned, and that emerging risks are flagged.

Group operations

To manage the risk of modern slavery in its own operations, the Group primarily relies on its MSA Policy and other policies referred to above, which are clearly communicated and understood throughout the organisation. The Group has training materials that explain modern slavery and set out indicators of potential modern slavery. These materials are available in both English and Bahasa Indonesia along with the Group’s related policies and procedures. All supervisory staff in Indonesia receive regular training, and this training information is then shared by them with their teams. Training on modern slavery is incorporated into the induction material for new joiners.

The Group sets itself the highest of standards when complying with local employment laws, health and safety, human rights laws and international standards. As a member of the Roundtable on Sustainable Palm Oil, (“RSPO”) the Group is subject to regular auditing by the RSPO to ensure it is satisfying the required standards. The Group’s longstanding practice is to ensure that its own workforce is directly employed by the Group and therefore benefits from its public commitment to being a responsible employer. When acquiring new planted areas, the Group also addresses modern slavery in its due diligence process, and following acquisition ensures that all new employees receive training on the Group’s modern slavery policies and protocols.

During the year, members of the Jakarta-based human resources department have again carried out estate visits during which they engage with workers on site. UK executives continue to visit operational locations throughout the year, and the visits provide an opportunity to assess the Group’s own adherence to its modern slavery policies.

In addition, the Group has a whistleblowing hotline run by an independent provider, accessed by telephone, email, WhatsApp or SMS messaging, which can be used to report any concerns about modern slavery. All reports received via the hotline are communicated directly to the UK whistleblowing officer and Group company secretary. To date there have been no reports indicating modern slavery within the Group or its contractors.

Suppliers and contractors

The Group continues to regard external contractors as presenting the highest risk of modern slavery. In particular, there is perceived risk associated with construction workers engaged on estate infrastructure projects, and field workers contracted for planting and replanting projects. In response, a programme for monitoring contractors operating at Group locations has been developed, and deployed, to maintain vigilance for any signs of modern slavery occurring on the Group’s estates.

The Group makes its zero-tolerance position on modern slavery and human trafficking clear to all of its suppliers. It has developed a programme of regular training sessions for its major partners and has not encountered any resistance with this engagement initiative. All supplier agreements include modern slavery clauses, and the Group monitors its major suppliers on an on-going basis by direct engagement through a programme of site visits. The procurement protocol also requires that suppliers complete a modern slavery questionnaire. In a step towards addressing the challenges of due diligence beyond the Group’s immediate contractual partners, consideration is being given to extending these questionnaires so that contractual partners will be required, in turn, to seek assurances from their own suppliers, thus building a chain of accountability.

Buying fresh fruit bunches from independent smallholders in some ways presents the greatest due- diligence challenge, due to the number of individual sources involved and the tendency for some consignments to be aggregated. However, the Group’s teams on the ground are devising outreach programmes for communities close to the Group’s estates and intend to communicate the Group’s expectations around labour practices in the production of fresh fruit bunches.

The Group also continues to work on a specific project with independent smallholders, supporting their journey towards certification under the RSPO’s RISS (RSPO Independent Smallholder Standard) scheme. This includes delivering training on guarding against modern slavery.

Ongoing priorities

The Group remains committed to addressing modern slavery and human trafficking as a relevant risk to the business. The most senior levels of management will continue to engage regularly with the organisation’s business areas via the modern slavery committee to promote on-going development of due diligence initiatives beyond the Group’s immediate partners. Staff training will be kept up to date, and management will ensure that clear information materials are prominently displayed in estates. The Group will continue to focus on working with its key contractors and suppliers, through both on-site monitoring and visits and communication of its zero-tolerance approach. The Group will also engage with its co-investor companies to communicate the Group’s zero-tolerance approach to modern slavery and human trafficking.