Modern Slavery Statement

27th April 2026

Croud Inc Ltd. makes this Modern Slavery Statement on behalf of itself and the entities listed in our organisational structure below, pursuant to section 54(1) of the Modern Slavery Act 2015 (the "Act"). It constitutes our modern slavery and human trafficking statement for the financial year ending 31st March 2026.

Our approach

At Croud, our company values of 'In it Together', 'Eye on the Future', ‘Generous in Spirit’, ‘Do what you say’ and 'Make a Difference' guide the way we conduct business. We are committed to ensuring that modern slavery and people trafficking are not part of our supply chain. We hold ourselves to the highest professional standards and expect our suppliers to do the same through robust policies, risk-based assessments, and mandatory awareness training.

Organizational structure

Croud Inc Ltd is a global provider of digital marketing solutions. Croud Inc Ltd (Company No. 07542498) is owned by Croud Holdings Ltd and operates the following entities:

• UK Entities: Born Social Ltd., and Serpico Marketing Solutions Ltd.
• International Entities: Croud MENA DMCC and Croud Incorporated (USA).

Supply chains

As an office-based service company, Croud’s supply chain consists primarily of:

• Office Suppliers: Facilities management, utilities, waste management, and consumables.
• Digital Marketing Suppliers: Third-party partners providing services such as paid search and social media advertising.
• Business Operating Suppliers: Professional services, including law firms, accountants, production, and IT providers.

Policies & governance

Our Supplier Code of Conduct sets out the minimum ethical, legal, and operational standards expected of all suppliers.

• Mandatory Compliance: We operate a strict contractual process in which every supplier must agree to comply with our Code of Conduct before onboarding.
• Legal Standards: Suppliers must comply with the UK Modern Slavery Act 2015 and all applicable labour and human rights legislation.
• Core Protections: The Code ensures that forced labour, servitude, and modern slavery are not present within supplier operations or supply chains.
• Reporting Obligations: Suppliers must notify Croud without undue delay if they become aware of any actual or suspected breach relating to modern slavery or labour exploitation.

Due diligence & risk management

Croud employs a tiered, risk-based approach to supplier due diligence:

• Standard Onboarding: Every supplier must read, understand, and sign the Supplier Code of Conduct as a condition of doing business with Croud.
• Risk-Based Vetting: For engagements identified as higher risk, Croud performs proportionate assurance activities. This includes requiring a Self-Assessment Questionnaire (SAQ) and a Security Review to evaluate business maturity and compliance levels.
• Continuous Monitoring: We have implemented periodic assessments of our supply chain post-onboarding to ensure standards are maintained and to identify emerging risks.

Training & awareness

Croud ensures that all employees have a clear understanding of modern slavery risks.

• Annual Training: We train our employees annually on how to recognise and escalate concerns.
• Mandatory Induction: Training is mandatory within the first week of an employee or contractor joining the business.
• Internal Resources: Our Modern Slavery Policy is reviewed annually and hosted on our internal intranet for all staff to access.

Key performance indicators (KPIs)

• 100% of suppliers agreed to the Supplier Code of Conduct.
• Completion of risk-based SAQs and security reviews for all high-priority service providers.
• Annual review of policies and supply chain risk profiles.
• Mandatory modern slavery training is completed by all staff and contractors.

Board approval

This statement has been reviewed and approved by a member of the Board of Directors at Croud Inc Ltd.

Signed

Date: 20th April 2026

Jeremy Summerfield, CFO, Croud Inc Ltd.