Modern Slavery Act

MODERN SLAVERY ACT (“MSA”) STATEMENT

Index Ventures (UK) LLP and Index Venture Services Limited, together "Index Ventures" (references to “we” or "our" should be construed accordingly).

OVERVIEW

At Index Ventures, we recognise the importance of ensuring that our business is conducted responsibly. We take a zero-tolerance approach to forced labour or human trafficking occurring in our business or supply chains. We are actively looking at ways to improve our practices and are committed to enhancing our diligence and vetting processes to better identify and mitigate various risks, including those of slavery or human trafficking, in our supply chain and business activities. With that, we noted and reflected on the UK Home Office’s recently updated statutory guidance on transparency in supply chains and started implementing its recommended Level 1 disclosures in a manner proportionate to our business activities, model and size and to the extent applicable. The consequential updates to date are incorporated below.

BUSINESS STRUCTURE AND SUPPLY CHAIN

As a venture capital advisory business that is office based, with fewer than 50 employees and regulatory clients being the affiliated Jersey based Fund Managers (the “Fund Managers”), we consider the risk of forced labour or human trafficking existing in the primary value chain to be very low.

There is a low modern slavery risk in our secondary value chain, that is, the goods and services we purchase from our suppliers. These primarily relate to property, catering, cleaning and facilities maintenance (i.e. ongoing supplier relationships) and we put adequate mitigants in place to further reduce the associated risk. For example, we evaluate the direct suppliers as part of our third-party due diligence process, by: (i) carrying out research on the prospect; (ii) meeting the prospect in person; (iii) seeking appropriate references from prospect’s clients; (iv) seeking to include appropriate protections (which allow termination for associated breach) in our supplier contracts to mitigate associated legal, regulatory, and ethical risks; (v) dependent on the contract value, asking the prospect to complete our due diligence questionnaire; and (vi) taking any other steps to satisfy ourselves as to the quality of the prospect.

With regards to our ongoing investment advisory mandate from the Fund Managers, we perform adequate investment and legal due diligence, including financial crime and adverse media screening, at the pre-investment stage on all the prospective portfolio companies of the affiliated Jersey based Funds (the “Funds”) and may include appropriate covenants in the investment documents to minimise any residual risk. Post-investment, the Funds’ ability to influence the portfolio company is limited to the extent to which the Funds receive any control, including voting, rights, including the right to a board seat. In addition, most of their portfolio companies are in the early stages of their development and as such, not subject to the MSA in the first place. Nevertheless, the Funds, acting through their Fund Managers with support from Index Ventures as required, are supportive of the portfolio companies’ initiatives in addressing these risks and willing to offer guidance as and when requested.

POLICIES AND PROCEDURES

We have in place a variety of internal-facing policies and procedures available online to all staff, reviewed and updated at least annually, designed to address our wider commitment to promoting responsible business practices. They cover topics such as gifts, entertainment and hospitality, anti-financial crime, anti-harassment, bereavement, grievance, health and safety and data protection among many others.

The staff are expected to periodically attest their compliance with the relevant policies. Any major updates to the policies are communicated to staff via email.

RISK MANAGEMENT

In summary, as part of our initiative to identify and manage risk:

• We are monitoring and reviewing our systems on an ongoing basis to better (a) identify, assess and navigate potential higher risk areas in our supply chains, (b) mitigate the risk of slavery and human trafficking occurring in our supply chains through more robust contract terms (where relevant), and (c) train our employees as to these risks and the need to manage them.
• We maintain and periodically review a central risk register which identifies all risks identified as relevant to our organisation.
• We continue carrying out the due diligence measures on our suppliers as described above.
• We endeavour to build long-standing relationships with our key suppliers and ensure that expectations of business behaviour are clear and consistent.
• We will not hesitate to terminate a relationship with any supplier where their business conduct falls below our expectations and standards, as described above.

Since 2023, we have become a member of VentureESG, to help us stay informed of the latest market practice covering sustainability more broadly (including human rights considerations, in the context of adequate due diligence for example).

IMPLEMENTATION

Our Board continues to be ultimately responsible for the implementation of the objectives considered in this statement.

The Board is supported by legal/compliance team, working with external legal and compliance advisers as needed, in the achievement of these objectives. The legal/compliance team also monitor progress of our efforts in this area and report back to the Board directly.

TRAINING

We provide our staff with annual training, including in-person training for new joiners, on a range of compliance matters which for all relevant members of staff now includes dedicated training on the MSA requirements. The annual training includes a dedicated online training module on modern slavery for relevant members of staff who more directly and regularly interact with suppliers, and who would be involved in selecting new suppliers.

MONITORING AND REPORTING

Any issues which are identified in relation to slavery and/or human trafficking must be reported to legal and compliance teams in the first instance. If material, they will also be reported to the Board.

This statement will be reviewed annually and published on our website.

The Board of Index Venture Services Limited approved this statement for itself and on behalf of Index Ventures (UK) LLP.

Signed for and on behalf of Index Ventures (UK) LLP and Index Venture Services Limited:

Simon Cunningham

As the Corporate Member Representative of Index Ventures (UK) LLP and Director of Index Venture Services Limited

Date: September 2025