Modern Slavery Act 2015

Modern Slavery Policy: Woodville Consultants Limited

Introduction

It continues to be a priority for Woodville Consultants Limited (“Woodville”) to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain. This statement highlights the key activities we have undertaken during this financial year to combat modern slavery in our organisation and supply chain.

This policy relates to our commitments during the current financial year 1 January 2025 to 31 December 2025 and applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third party representatives and business partners.

Responsibility for the Policy

The Senior Management Team has overall responsibility for ensuring that this policy complies with our legal and ethical obligations and that all those under our control comply with it.

• Our Human Resources (HR) team Bright HR ensure that our recruitment practices always comply with human labour rights legislation. The team must also ensure that key employees are given adequate and regular training on modern slavery in supply chains.
• Management at all levels are responsible for ensuring that those reporting to them understand and comply with this policy.
• Our Legal Counsel Birch Law Limited is responsible for ensuring that our supply chain suppliers are obliged to comply with all applicable laws, including the Modern Slavery Act 2015 in their contracts with the Company.
• All persons working for us or on our behalf in any capacity must read, understand and comply with this policy. They must notify their manger as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.

Comments or queries regarding this policy should be addressed to Ann Marie Bell

1. Organisation’s structure, its business and supply chains

We are a litigation funder in the legal claims sector, funding third party consumer claims such as housing disrepair and PCP claims. We provide law firms with litigation funding to fund the acquisition and progression of legal claims. Our head office is located at 5 Gelliwastad Road, Pontypridd, Wales, CF37 2BP and we operate throughout the United Kingdom.

We have over 12 employees.

We have a global annual turnover of £52m (year end 2024).

Organisation and supply chain structure

We are a UK based litigation funder providing business to business funding to UK SRA regulated law firms. Woodville solely lends to organisations in the UK. Woodville receives funder investments in from all over the world predominantly from the following regions: UAE; Latin America; Europe. Both sides of the organisation are run through Woodville. Inward investment comes in and is onward lent to UK regulated law firms. Contracts with UK placement agents (introducers) liaise directly with the offshore advisers through whom investments are sought. These being onward lent to long term partnerships held with UK law firms.

Supply chain understanding

We recognise that it is crucial for us as an organisation to have oversight of our supply chains so that we can understand the risks of modern slavery along the chain and take action to mitigate against those risks.

Products, sectors and services

We also maintain records of our services, and the sectors we operate in. These records are kept by and reviewed annually by our Senior Management Team.

Direct and indirect suppliers

We also maintain records of all of our suppliers, both direct and indirect, including: (a) Bright HR (HR requirements); (b) External Auditors (Xeinadein – Liverpool); (c) Banking (HSBC); (d) IT (Sharp); and (e) Legals (Birch Law Limited).

Modern slavery risk management governance

We ensure that we have identified named individuals and specific departments within the organisation to be responsible for our modern slavery risk management. The person within Woodville with: (a) overall responsibility for our modern slavery risk management including identifying, assessing and responding to modern slavery and governance structure; and (b) that provides senior level oversight and management of the modern slavery risk, is Ann Marie Bell.

Information gathering for the statement

The organisation ensures that it gathers information to respond to the MSA 2015 legislative requirements, including: internal consultations with key members of senior management; review and consultation with external advisors, such as Birch Law Limited and Bright HR.

Stakeholder engagement to map supply chains

As part of our work in mapping our supply chains, we engage extensively with external stakeholders. These include: (a) Bright HR (HR requirements); (b) External Auditors (Xeinadein – Liverpool); (c) Banking (HSBC); (d) IT (Sharp); and (e) Legals (Birch Law Limited).

Inward investment, department leads being Mark Palmer / Peter Legge. HR and Legals – Ann Marie Bell and Angharad Price. Law firm liaison (agreements case tracking) Ann Marie Bell / Angharad Price. IT – David Palmer

Continuous improvement of operations and supply chain knowledge

This year, our organisation has aimed to improve our knowledge of operations and supply chains by: (a) keeping abreast of all industry factors that affect the ongoing day to day running of the business; as well as (b) regular review meetings with all third party suppliers.

2. Our policies on slavery and human trafficking

We aim to have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies.

Internal operating policies

Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls aiming to ensure slavery and human trafficking is not taking place in our supply chains. We also have the following policies in place relevant to modern slavery, which we continuously review and update:

• Employee code of conduct;
• Recruitment (including prohibiting the use of worker paid recruitment fees);
• Freedom of workers to terminate employment;
• Prohibiting any threat of violence, harassment and intimidation;
• Prohibiting compulsory overtime; and
• Prohibiting child labour.

Stakeholder engagement on modern slavery policies

We engage with various stakeholders to inform both the development and implementation of modern slavery policies. All development and implementation of modern slavery policies are provided and reviewed by Bright HR.

Communication and enforcement of policies

We aim to communicate and enforce policies within the organisation and to suppliers and subcontractors by: (a) via Department heads in the field in which they become relevant; and (b) face to face meetings followed by written confirmations of any actions required.

Supplier’s policies

The organisation has assessed various of our supplier’s policies and practices: All of our suppliers are UK based SRA regulated law firms, who will all have their ow policies and procedures in place as a requirement for their Regulator – The Solicitors Regulation Authority.

3. Due diligence processes for slavery and human trafficking

In this section we will provide information on the due diligence programmes and processes we use in our business and supply chains in relation to slavery and human trafficking. Due diligence in this context includes identifying, assessing, monitoring and mitigating any risks. We will explain our approach under the following headings:

• Prevention and mitigation.
• Supplier and worker engagement.
• Our human rights due diligence approach.
• The grievance mechanisms we have in place.
• Our remediation policies and processes.
• Incidents of modern slavery.
• Our business model assessment.
• Stakeholder engagement on due diligence programmes.
• Continuous improvement in due diligence approach.

Prevention and mitigation

As part of our initiative to prevent and mitigate the risk of slavery and human trafficking we: carry out ongoing reviews of our internal policies; and work closely with our HR company to ensure that we are kept abreast of all developments.

Supplier and worker engagement

As part of our due diligence processes in relation to the risk of slavery and human trafficking, we intend to conduct the following supplier and worker engagement: (a) we propose to engage with our suppliers through questionnaires, onboarding assessments and contractual clauses requiring compliance with Modern Slavery Act 2015; and (b) where appropriate, we will request supporting documentation such as anti-slavery policies, training records and audit reports.

Human rights due diligence approach

Specifically in relation to our approach to human rights due diligence, we intend to conduct due diligence in line with UN Guiding Principles on Business and Human Rights. We will assess modern slavery risks in our supply chain annually, reviewing high risk jurisdictions and sectors. All suppliers will be asked to confirm adherence to human rights and labour standards.

Stakeholder Engagement on Due Diligence

We engage with both internal stakeholders and external advisors (e.g. Birch Law Limited) to assist with our due diligence process. Engagement occurs through periodic reviews, supplier audits and compliance discussions.

Grievance mechanisms

As part of our approach to prevent and mitigate the risk of slavery and human trafficking we have certain grievance mechanisms in place: whistle-blowing policy found within our employee handbook to ensure workers have a means by which they can report concerns and access remedies.

Remediation policies and processes

As part of our approach to prevent and mitigate the risk of slavery and human trafficking we will ensure that we have sufficient remediation policies and processes in place. In the event that modern slavery is suspected or confirmed we will:

• Immediately investigate the concern through our HR and Compliance teams, supported by external legal advisors where necessary;
• Take corrective action to address the issue, which may include requiring the supplier or partner to implement a remediation plan, provide restitution to affected individuals, or terminate the business relationship if remediation is not possible or cooperation is refused;
• Support affected individuals where possible by working with specialist NGOs or government agencies to ensure their safety and access to remedy, including support services or safe working conditions;
• Record and report the incident to senior management and, where appropriate, notify relevant enforcement authorities;
• Review and improve internal processes to prevent recurrence, including revisiting due diligence processes and contractual protections.

We treat any substantiated case of modern slavery with the utmost seriousness and consider it a breach of contract and company policy. Our remediation process reflects our zero tolerance approach and commitment to continuous improvement.

Incidents of modern slavery

We are unaware of any incidents of modern slavery taking place within Woodville.

Business model assessment

We have conducted a business model assessment of whether our business model and KPI’s may in some way cause, contribute or directly result in modern slavery in our operations and supply chains.

We have considered as an organisation whether or not our business model may cause modern slavery, however as we are only a small (in number of employees, 12 business) this can be constantly reviewed in house through regular employee reviews of not only what we ask of them but in a review of any complaints coming from them, via the HR platform all have access to.

Continuous improvement of due diligence approach

During the current financial year our organisation has continued to monitor our diligence approach and processes to ensure that it meets all necessary requirements.

4. Identifying, assessing and managing risk of slavery and human trafficking

We regularly carry out a modern slavery risk assessment including identifying, assessing and managing the risk of slavery and trafficking within our business and supply chains. This section of our statement will include discussion under the following headings:

• Risk assessment frequency.
• Risk assessment governance.
• Identifying and assessing the risks.
• Highest priority risks.
• Stakeholder engagement on the risks.
• Continuous improvement in risk assessments.

Risk assessment frequency

We ensure that our modern slavery risk assessment is carried out regularly, with the aim of completing an assessment annually.

Risk assessment governance

Ann Marie Bell (supported by external HR) is responsible for our modern slavery risk assessment.

Identifying and assessing risks

We aim to use a variety of different sources for identifying and assessing our organisation’s overall modern slavery risk. By regularly reviewing the materials from Bright HR and ensuring our policies and procedures are up to date. Regular engagement with our Employees, through regular reviews.

Highest priority risks to workers

We aim to identify the highest priority modern slavery risks to workers within our business and supply chains.

We feel this is minimal as suppliers are all UK regulated law firms who will have their own measure in place as part of their regulatory responsibilities to the SRA.

Stakeholder engagement on the risks

As part of our modern slavery risk assessment programme, we will be engaging with workers and other stakeholders, both internal and external to inform our approach.

5. Monitoring and evaluation: our effectiveness in combating slavery and human trafficking

This section sets out our anti-slavery goals (MSA Goals) which aim to improve our ability to identify, prevent, mitigate and respond more effectively to modern slavery risks in our business and supply chains. Our MSA Goals have been informed by specific risks we have identified in our operations and supply chains. We use a set of key performance indicators (KPIs) to measure how effective we have been in achieving our MSA Goals.

MSA Goal setting

At Woodville, we are committed to the continuous improvement of our efforts to prevent modern slavery and human trafficking. To ensure we are meeting our obligations under the Modern Slavery Act 2015 and strengthening our internal controls, we have established the following Modern Slavery Act (MSA) goals for the current financial year:

• Enhanced Supplier Due Diligence. Implement improved due diligence procedures for all new and existing suppliers, including the introduction of modern slavery risk screening and contractual clauses requiring compliance with applicable anti-slavery laws.
• Increase Training Coverage. Ensure that 100% of relevant staff, particularly in procurement, HR, compliance and legal complete annual modern slavery training, including recognising red flags and escalation procedures.
• Risk–Based Supply Chain Review. Identify and assess modern slavery risk in high value and high risk areas of the supply chain, especially focusing on overseas investment introducers and third party agents. Document outcomes and mitigation strategies.
• Policy Integration and Awareness. Integrate anti-slavery standards into broader company policies (e.g. procurement, onboarding and whistleblowing) and ensure policies are accessible and understood across all departments.
• Incident Responses Readiness. Develop and communicate a formal incident response protocol for suspected cases of modern slavery, outlining steps for investigation, reporting, remediation and stakeholder engagement.
• Improve Reporting Mechanisms. Strengthen internal and external reporting mechanisms, including anonymous whistleblowing procedures to encourage the reporting of concerns without fear of retaliation.

These goals are reviewed annually by senior management and progress is tracked through measurable KPIs and internal audits. They are intended to reinforce our commitment to ethical conduct, transparency, and the protection of human rights across our operations and business relationships.

Key Performance Indicators (KPIs)

In the same way as we establish a set of MSA Goals, we set a number of outcome-focused KPIs in order to measure progress towards these goals. To measure our effectiveness in ensuring that slavery and human trafficking is not taking place in our business or supply chains, we intend to track the following KPIs going forward:

• Percentage of staff trained on modern slavery risks (target 100%);
• Number of supplier assessments completed (target 100% of new suppliers);
• Number of reported incidents and follow up investigations (target zero tolerance); and
• Frequence of internal policy reviews (annually).

These KPIs are monitored by Ann Marie Bell and reported to the Board annually.

Monitoring and evaluation governance

We have distinct identified individuals within the organisation who are responsible for establishing our MSA Goals and KPIs. Ann Marie Bell is responsible for establishing our MSA Goals and KPIs.

Stakeholder engagement on monitoring and evaluation

As part of our monitoring and evaluation we engage with both internal and external stakeholders to inform our approach.

6. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. We provide targeted training to our staff to raise awareness of modern slavery and trafficking risks. This includes: (a) annual mandatory e-learning for all staff on recognising signs of modern slavery; (b) in depth training for HR and procurement staff on supplier due diligence; and (c) scenario-based workshops for senior management. Training effectiveness is reviewed yearly, and updates are made based on changes in legislation or risk profiles.

Training programme materials

To support our commitment to preventing modern slavery and human trafficking we provide targeted training to ensure our employees and relevant stakeholders understand the risks and how to respond appropriately. Our training programme uses a variety of methods and formats to suit the needs of the different roles within the organisation. Training programme is provided by Bright HR.

Further steps

Following a review of the effectiveness of the actions we have taken this year to combat the risk of slavery and human trafficking in our businesses and supply chains, we intend to take the following further steps in line with our commitment to continually improve and strengthen our approach year-on-year: (a) carry out bi annual reviews of our policies and consult with external legal and HR advisors to ensure that our policies are kept up to date; (b) offer senior management external training courses throughout the year to ensure that they are abreast of all and any developments.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for January 2025 – December 2025. It was approved by the board on 5 November 2025 .

Ann Marie Bell

Woodville Consultants Limited

Date: November 6th, 2025