MODERN SLAVERY STATEMENT

A) ORGANISATION

This statement applies to Gallowglass Security Limited all companies within and associated to Gallowglass Security Limited (Company number 16570641) The information included in this statement refers 2025/2026.

B) ORGANISATIONAL STRUCTURE

We are a supplier of security services, and it is regulated by the Security Industry Authority (SIA). The registered office of Gallowglass Security Limited is located at 1-5 Beehive Place, London, SW9 7QR.

Ownership of the Gallowglass is vested in one shareowner, namely Mr Giles Turnbull and he is the person with significant control.

He is supported by a tier of executive management who are responsible for operations, legal and compliance, finance, HR, H&S, logistics, and administration.

Service provision is provided by a pool of SIA licensed guards, who are graded according to experience and ability into one of three tiers: Security Officer (SO), Senior Security Officer (SSO), and Team Leader (TL). We select TLS’s from our pool of SOs and SSOs. Seniority is rewarded by enhanced rates of pay.

C) DEFINITIONS

Gallowglass considers modern slavery to be abhorrent and cruel and encompass:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse or the threat of
  abuse;
• Being dehumanised, treated as a commodity, or bought/sold as property;
• Being physically constrained or having restrictions placed on freedom of movement.

D) COMMITMENT

Gallowglass acknowledges its responsibilities in relation to tackling modern slavery and commits to
complying with the provisions in the Modern Slavery Act 2015. We understand that this
requires an ongoing review of both its internal practices, in relation to its labour force, and its supply
chains.

Gallowglass does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports, or is found to involve itself in, slavery, servitude and forced or compulsory labour.

No labour provided to us in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Gallowglass strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.

E) SUPPLY CHAINS

In order to fulfil its activities, our main supply chains include those related to manpower,
professional services, vehicles, IT, office hardware, and clothing. Its supply chains are sourced from
the United Kingdom.

F) POTENTIAL EXPOSURE

Gallowglass considers its main exposure to the risk of slavery and human trafficking to exist in labour
provision; rigorous steps have been undertaken to minimise this risk.

In general, Gallowglass considers its exposure to slavery/human trafficking to be relatively limited.
Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the
business of any organisation that supplies goods and/or services to it.

G) STEPS

Though not required to by law, Gallowglass will, since the formal inception of this policy, extend to all non-manpower suppliers (we have had independently verified employee safeguards in place since
2007 to prevent modern slavery in our manpower supply chain) due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its supply chains, including
conducting a review of the controls of its suppliers.

Gallowglass has not, to its knowledge, conducted any business with another organisation which has
been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Group has operated British
Standard 7858:2021 (security screening) to ensure that modern slavery does not in any way feature
in our workforce.

The measures pursuant to this standard are as follows:

• ID verification and right to work check (pursuant to the Asylum and Nationality Act 2006)
• the first and most well-used checks in pre-employment screening, being critical for all employment in the UK). These checks must be accompanied by copies of original identification documents such as passport, driving license and/or birth certificate.
• Obtaining bank details which must correspond to the applicant and not a third party or
  third party organisation.
• A 5 or 10-year written career history – which involves an analysis of all periods of
  employment, as well as confirmation of employment gaps of up to 31 days. It also
  includes analysis of any periods of self-employment.
• A financial probity check (includes bankruptcy, IVA and insolvency checks, and checks for
  CCJ’s up to £10,000).
• Criminal records screening to a level of Basic disclosure, which details unspent criminal convictions and conditional cautions.
• Global watchlist check (cross-referencing the individual’s name(s) against various
  sanctions, watchlists and fraud databases, including, but not limited to, the HM Treasury’s consolidated list of financial sanctions targets in the UK).
• The information gathered as part of the BS7858 is kept for 7 years after the end of

Our compliance with this standard is undertaken annually pursuant to our ISO 9001:2015 annual renewal surveillance visit, when all our processes are subject to an independent inspection from a UKAS approved assessing body.

Additionally, we propose to undertake a due diligence review of all of our suppliers to confirm
what measures they have undertaken to prevent slavery within their organisations and supply
chains.

We will review our supplier contracts to include termination powers in the event that the supplier is,
or is suspected, to be involved in modern slavery.

We will extend training for all staff members on how to identify potential evidence of slavery and
trafficking amongst applicants and within the workforce.

H) POLICIES

Gallowglass has the following policies which further define its stance on modern slavery, particularly in relation to the workforce, where all employees are on Peninsula based HR employment contracts in which their statutory employment rights are enshrined. This includes a robust grievance policy.

I) TRAINING

The Group will provide the training to all staff, so they know how to recognise signs of modern slavery and to whom it should be reported; as well as implementing its stance on modern slavery. The slavery syllabus will be devised by our in-house trainers, who are both professional ex-teachers, and will be delivered in person through toolbox training.

J) SLAVERY COMPLIANCE OFFICER

Gallowglass has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should
be addressed, and who will then undertake relevant action with regard to our obligations in
this regard.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be
reviewed for each year.

Name: Anna Borucinska

Date: 1^st September 2025

Expiry: 31^st August 2026