01 — Business Organisation and Structure

This statement is made by and on behalf of EVBox (hereinafter referred to as “EVBox”). EVBox is active in the designing, manufacturing, assembling and supplying charging solutions for electric vehicles and carries on part of its business in the UK. EVBox is headquartered in Léognan, France

Our supply chain involves suppliers providing goods and services in relation to the products and services we offer (direct procurement), to our office needs and to running our business (indirect procurement).

02 -Policies

We are committed to the highest standards of ethical and legal business conduct, and we expect our suppliers to share the same commitment. We have developed  ethics and compliance policies, principles, and commitments, and implemented them into our business and culture. EVBOX’s commitment to the respect for human rights, including explicitly the rejection of forced labor, is laid down in the following documents.

EVBOX’s Ethics Code of Conduct defines the fundamental principles underlying our overall ethical commitments and policies. It provides guidance to help our employees make the right decisions in a range of business practices. “Respect for human rights” is one of the fundamental principles, under which the EVBOX’s commitments include: a respectful and inclusive work environment; combatting violence, moral or sexual harassment, and sexist behavior; refusal of forced labor and child labor; respect for freedom of association; and respect for the rights of local communities. Taking human rights into account in the exercise of its activities is a fundamental requirement for EVBOX’s.

This Ethics Code of Conduct strengthens the speak-up culture at EVBox and provides employees with information and tools to raise concerns. In addition, as required by law, we have adopted a Whistleblowing mechanism, implementing the EU Whistleblowing Directive (adopted in 2021)

Reporting channels. As part of the EVBox’s determination to deepen our commitment to ethics and to allow anyone to report inappropriate situations or those that are not in line with our principles, policies, or current laws and regulations, we have put in place internal reporting channels.

Our Ethics Code of conduct and our Employee Handbook reinforce the importance of creating an equitable, diverse and inclusive working environment. It contains EVBox commitments to a workplace free from discrimination, harassment, bullying and victimization, treating everyone fairly and with respect, and creating equal employment opportunities, among others.

The Code of Conduct for EVBox Supply Chain, strengthens commitments to compliance in our supply chain. Among other things, our suppliers are required to uphold the principles of equal opportunity and fair employment practices in all aspects of their operations, avoid any form of discrimination, not to engage in nor tolerate the use of forced labor, child labor and any form of human trafficking, and provide a safe and healthy working environment across all locations where work is undertaken.

03 — Due Diligence and Risk Assessment

We have identified key stakeholders in the relationships with suppliers within our organization to identify risks and put in place processes and appropriate measures to assess, manage and minimize the risks of modern slavery within our supply chains.

We have set up a Governance, Risk and Compliance (GRC) Committee. As part of the GRC Committee activities, we created the Risk Register, which contains key risks across the organization, including the compliance risks.

Risk assessment. With regard to our business organization, our Tier 1 supply chain (as described below), we generally consider the country risk low, due to a more limited exposure to the countries where protection against breaches of human rights is limited. Taking into account the type of EVBox business, we also consider the sector risk low. However, we recognize there might be suppliers involving potentially higher risks both in Tier 1 and further down the supply chain. In view of that and taking into consideration the size of our business and available resources, we are gradually enhancing our third-party risk management processes, as described below.

Our workforce. As an employer of highly skilled and predominantly highly qualified talent, the risk of modern slavery within our business is considered low. We exclusively employ in France and European countries. Our HR and employment policies and practices are aimed at ensuring fair recruitment, equal opportunities, and a secure working environment for all employees. All candidates undergo the same selection process and are employed under the same terms.

Our supply chain. Our Tier 1 suppliers in direct procurement are located primarily in the EU with a limited number in China.

Due Diligence. New Tier 1 suppliers undergo a supplier selection assessment, which, among other things, includes an assessment of the working conditions and a question regarding human rights and anti-modern slavery actions. We recognize there are suppliers involving potentially higher risk and apply additional measures.

Contractual mechanisms. When establishing relationships with new suppliers, we aim at ensuring that each contract includes a commitment to uphold the principles covered by our policies. The Code of Conduct for EVBox Supply Chain is an essential component of our standard supply contracts. It mandates that our suppliers guarantee their compliance (and ensure compliance further down the supply chain) with all relevant laws, including those related to human rights, child labor, and forced or compulsory labor.

Our standard contract templates also grant EVBox the right to conduct audits in order to verify suppliers’ compliance with our policies. If an audit reveals that a supplier has violated the Code of Conduct for EVBox Supply Chain, the supplier must promptly take corrective actions and we reserve the right to conduct a subsequent audit. When the second audit shows that the supplier has not implemented any corrective measures, we have the option to terminate the contract.

By offering suppliers the opportunity to rectify non-compliance issues, rather than resorting to a strict punishment in the form of contract termination, we encourage them to improve their operations. This approach effectively contributes to the advancement of working conditions across the industry. At the moment, we do not have resources to specifically audit suppliers other than Tier 1 suppliers.

04 — Training

We regularly conduct ethics and compliance training sessions covering such topics as ethical principles, reporting and whistleblowing, ethics in business relationships with customers, suppliers and other third parties.

In addition to the mandatory trainings, we have been raising awareness of ethics and compliance topics and our “speak up” culture and promoting the use of the reporting channel through awareness campaigns. Through these initiatives we hope to create an environment in which employees will feel comfortable raising issues that they spot in our business, which allows us to constantly improve our company and operations.

05 —Approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2025.

This statement has been approved and signed:

Eric Stempin

CEO