Anti Modern Slavery and Human Trafficking Statement

June 2024

INTRODUCTION

This Modern Slavery Statement has been published in accordance with the Modern Slavery Act 2015. This statement encompasses all group companies of Green (Topco) Limited, including all affiliates and subsidiaries, including The Instant Group (“Instant”) as of 01 June 2024.

We are committed to improving our practices to combat slavery and human trafficking. We are dedicated to understanding the risks and taking appropriate steps to ensure that there is no modern slavery in our business and supply chains.

Our Executive Board has overall responsibility for ensuring compliance with this Modern Slavery Statement.

ABOUT INSTANT

We exist to make work smarter for everyone: employees, businesses, and the planet.

For us, this means more than being the world’s largest marketplace for flexible workspace.

It means providing over 250,000 organisations around the world with everything they need to work smarter, whether that be office space, coworking memberships, virtual offices, or meeting rooms. As well as delivering the latest data and insights on the flex market or offering expert consulting services on portfolio strategy, procurement, and sustainability.

It means helping our landlord, operator and investor partners capture demand for flexible workspace and increase revenue by making assets work smarter for them.

By seamlessly connecting supply and demand and providing insight-driven advisory, data, and flex solutions, we help our partners transform their portfolio and stay relevant as the market evolves.

With over 24 years’ data and experience, Instant’s unique approach enables landlords, operators, and investors to build a smarter working world for today’s occupiers.

www.theinstantgroup.com

RISK ASSESSMENT

Our Employees

Instant globally employees more than 450 people who work in our offices, remotely and at our Clients sites.

Sector Risk: Low - Our employees work in a corporate environment which are comparatively lower risk.

Location Risk: Medium – We have a global employee base, some of these employees will work or reside within higher risk geographies.

Risk of occurrence - The risk is significantly reduced by the recruitment and people management controls we have in place.

Our Supply Chain

Instant do not manufacture any products or deliver them directly so working closely with trusted third-party suppliers is crucial to reducing the risk of modern slavery or human trafficking with our supply chain.

Our risk is derived from two core areas, firstly Instant’s Managed Office Solution, which provides turn-key design and build office services for our clients and landlords. Secondly from the technology suppliers we engage with to develop and maintain our web platforms and the technology installed within our managed solution.

Third Party Suppliers – These are suppliers we directly engage to predominantly deliver our Managed Solution and provide the products and services we sell to our clients; it also includes those which keep our business going, most prominently technology suppliers. We have an extensive global supply chain to support this.

Location Risk: Medium – Some of these suppliers may work on our client sites, (including construction workers, cleaners, facilities, and food services providers. Some of these will work in higher risk geographies, all will be subject to a degree of monitoring by an Instant employee.

Risk of Occurrence: High - There are locations and sectors in which our suppliers operate where modern slavery if more prevalent. Particularly in the higher risk services sectors listed above where we are aware of higher instances of industry wide issues.

We have moderate influence and control over these supply chains. We directly select these suppliers and specify the good or services they offer us, but we rely on these suppliers to operate on our behalf. There are several stakeholders involved internally in addition to our procurement team who select and manage these suppliers.

OUR POLICIES

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our supply chains include firms that provide elements of workspace lifecycle such as design, fit out, facilities management and technology. Our approach is embedded within our policies and employment practices. Our Managing Director, Client & Partner Services and Chief Technology Officer have full responsibility for managing the supply chain relationships within their remit.

We expect our suppliers to comply with all laws and regulations including anti-slavery and human rights principles in employment. The policies and processes we have in place to help us identify and mitigate risk areas include the following: -

• In accordance with our Procurement Policy and supplier selection process, All Instant suppliers are required to complete a comprehensive supplier onboarding Questionnaire and supplementary Pre-Qualification Questionnaire which assess the supplier's level of compliance with relevant requirements and outlines their approach to managing their own supply chain to comply with Instants compliance and governance requirements.
• Suppliers are required to comply with our Supplier Code of Conduct which includes anti-slavery and human rights commitments as well as obligations relating to fair labour practices.
• In 2023 we launched our Supplier Health, Safety & Environment Standards, providing further operational definition on what we expect from our Supply Chains.
• We review the Global Slavery Index (Walk Free Foundation) prior to expansion into new territories and determine action plans where necessary.
• Our People policies and processes set out our expectations of, and Instants responsibilities towards our employees. Our policies are provided to new starters, and referenced in induction material, and are available on our My Instant platform.
• We review our new employees right-to-work as part of our onboarding process and have a Whistleblowing Policy which allows staff to raise concerns confidentially.
• Our approach to tackling modern slavery is also rooted within our Environmental Social Governance (ESG) Policy, ensuring we uphold the highest standard of ethical conduct across all business operations.

MONITORING COMPLIANCE

The following supplier management processes and steps enable us to ensure that our suppliers do not engage with any kind of anti-slavery and human trafficking practices: -

• Supplier Annual Review - We carry out an annual review which includes checks on supplier performance, policies, and compliance with our Supplier Code of Conduct.
• Supplier Staff Vetting - We conduct ad hoc checks on our major suppliers for compliance with relevant employment regulations including verifying that suppliers are paying local minimum wage.
• Inspections - Fit-out and construction projects are periodically inspected against our Supplier Health, Safety & Environment Standard.
• Contracts - We seek to include anti-slavery commitments in all supplier contracts and retain rights to audit our suppliers.
• Enhanced due diligence steps as we expand our business into new territories including enhanced procurement processes for supplier selection and onboarding processes.
• Developed appropriate due diligence and monitoring procedures for high-risk countries.

MEASURING EFFECTIVENESS

Within the business, our operations and legal divisions work together to ensure compliance with our anti-slavery and human trafficking policy. We can measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or within our core suppliers by:

• Assessing the risk through the annual audits we carry out on our core suppliers.
• Our requirement on suppliers to provide evidence that they have carried out appropriate staff training sessions.
• Our requirement on suppliers to provide evidence of subcontractor inspections and/or audits where appropriate.

Annual internal policy adherence review and associated follow up actions.

OUR PRIORITIES

In the next financial year, we aim to increase awareness of modern slavery and human trafficking. A new e-learning module will be launched to our  Managed Delivery, and Technology teams, and any other parties closely responsible for engaging suppliers. We will target a 90 % completion rate.

Additionally, we aim to enhance our Compliance Monitoring arrangements, and increase the scope and breadth of audits completed across our Supply Chain.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes The Instant Group’s slavery and human trafficking statement for the financial year ending 31st December 2023.

eSigned: Tim Rodber

CEO 

Green (Topco) Limited