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Modern Slavery Statement

Last Updated: 1ST JANUARY 2026

Policies on Modern Slavery

Horizons Casino remains fully supportive of the principles of the Modern Slavery Act 2015 (MSA) and we continue to improve our practices to better understand and mitigate the risks of slavery and human trafficking.

We maintain a zero-tolerance approach to trafficking and slavery. Although we do not yet have a standalone Procurement Policy or Supplier Code of Conduct, we have already embedded standard contract clauses to reflect our commitment to the MSA and to set clear expectations for our suppliers.

Supply Chain Risk Assessment

We have refreshed our risk assessment of the business and supply chain. We continue to consider our core business operations to be low risk in terms of modern slavery and human trafficking but have identified areas of higher risk, particularly in outsourced staffing and in food and beverage raw materials sourced abroad by our predominantly UK-based suppliers.

We work only with suppliers who comply with the MSA and who share our corporate values on human rights. As contracts renew, we have included contractual provisions to ensure compliance. Further due diligence, audits and supplier questionnaires are undertaken on a risk-based basis.

Organisations who fail to meet our standards risk the termination of their business with Horizons Casino.

Within the Company Risk Assessment

We currently employ approximately 200 staff, the majority directly employed. Outsourcing of staff is now rare. We remain committed to ensuring a safe and fair working environment that is free from modern slavery and trafficking. We check that all employees have the right to work in the UK and ensure that all are paid at least the National Minimum or Living Wage as applicable.

Horizons Casino maintains a corporate register which records all directors and senior officers. We conduct KYC searches on all directors and carry out ongoing monitoring of both directors and associated businesses. This enhances our oversight of potential risks within the company and our supply chain.

We have strengthened our internal policies during 2024–2025 to create a positive and safe workplace. These include policies covering positive work environments, harassment, sexual harassment, domestic abuse, whistleblowing, recruitment, and mental health and stress.

All staff receive mental health, domestic abuse awareness and sexual harassment awareness training via VIXIO, an independent e-learning and training platform. Training intensity is aligned to individual roles to ensure relevance and effectiveness.

All policies are accessible to staff via our HR system and encourage reporting of any activity that may be unlawful or in breach of company policies. Any outsourced staff are expected to adhere to the same standards.

Training for Staff

Ultimate responsibility for MSA compliance sits with the Board of Directors. The Group Financial Controller oversees Human Resources and Procurement-related activities and signs off the MSA Statement on behalf of the Board.

Training on the risks of modern slavery and human trafficking has been refreshed for all relevant departments during 2024–2025 to ensure continued high-level understanding.

Measuring Effectiveness

The Board of Directors retains ultimate responsibility for the implementation of Horizons Casino’s policies, including those relating to ethical trading and employee welfare.

Due to the overall low risk assessment, no formal MSA Key Performance Indicators have yet been established, however this remains under review.

Approval

Horizons Casino makes this statement pursuant to Section 54(1) of the Modern Slavery Act 2015. This MSA Statement has been reviewed and approved by the Horizons Casino Board of Directors on 17th December 2025.

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