Corporate Social Responsibility Policy

1. Overview

We are committed to operating responsibly, ethically and sustainably. This Corporate Social Responsibility (CSR) Policy reflects our responsibility towards the environment and all of our stakeholders — customers, suppliers, employees, investors and the communities in which we operate. We aim to make a positive impact through legal compliance, ethical practices and proactive initiatives.

Our CSR strategy is built on four pillars — Sustainability, Equity, Engagement and Diversity — which set out the initiatives, ownership and measures through which these commitments are put into practice, and through which we report progress in our annual Impact Report.

2. Scope

This policy applies to Odyssey Interactive Limited, trading as “Interact” (together, “we”, “us”, “our”), and our respective group companies and to all our employees and contractors worldwide, with a focus on our main offices in the UK and our engaged workforce in other locations. It governs how we operate ethically, socially and environmentally in all our business activities.

3. Our Approach

Our CSR approach is built around two operating principles: Compliance — meeting or exceeding our legal and ethical obligations — and Pro-activeness — going beyond compliance through our four CSR pillars.

4. Compliance

4.1 Legality

We ensure that all our business operations are legal, transparent and aligned with regulatory requirements, including:

  • Respecting all applicable laws, including anti-bribery, anti-corruption, anti-slavery and human trafficking laws in the UK and the other jurisdictions in which we operate;
  • Following internal policies and ethical guidelines, including our Code of Conduct;
  • Ensuring all partnerships, collaborations and supplier relationships are transparent; and
  • Conducting proportionate due diligence to ensure our supply chain is ethical and environmentally responsible, in line with our Supplier Code of Conduct.

4.2 Business Ethics

We conduct business with integrity and respect for human rights by:

  • Promoting fair dealings and safe working environments;
  • Respecting employees, customers and suppliers;
  • Applying anti-bribery and anti-corruption standards across all operations; and
  • Ensuring ethical marketing and responsible product and service practices.

4.3 Protecting People and Human Rights

  • Maintaining health and safety standards that meet or exceed legal requirements;
  • Ensuring our activities do not violate human rights directly or indirectly;
  • Adhering to fair working practices and providing competitive remuneration and benefits, paying above the applicable national living wage in every jurisdiction in which we employ people; and
  • Respecting freedom of association and employees’ lawful rights of representation.

4.4 Anti-Slavery and Human Trafficking

We recognise the low risk of slavery or human trafficking in our operations but actively mitigate that risk through:

  • Compliance with the UK Modern Slavery Act 2015 and publication of an annual Modern Slavery Statement;
  • Anti-slavery obligations in our Supplier Code of Conduct and supplier contracts, including the prohibition of worker-paid recruitment fees and the retention of identity documents; and
  • Due diligence on new suppliers proportionate to risk and fair and timely payment of suppliers.

5. Pro-Activeness: Our Four Pillars

5.1 Sustainability

We proactively reduce our environmental impact beyond compliance:

  • Measuring and reducing our carbon footprint across Scopes 1, 2 and 3, with an emissions baseline and annual reporting;
  • Operating from energy-efficient premises — our principal Manchester office, Windmill Green, holds BREEAM Outstanding accreditation, with segregated waste streams and a 100% diversion-from-landfill rate;
  • Enabling low-carbon commuting and travel, including our electric vehicle salary sacrifice scheme (UK), cycle to work scheme and encouragement of rail over air travel where practicable;
  • Supporting reforestation through our tree-planting partnership, linked to business travel emissions; and
  • Operating digital-first, paper-light processes and responsibly recycling IT equipment at end of life.

5.2 Equity

We ensure our people are rewarded and treated fairly:

  • Benchmarked pay bands to remain competitive and consistent across the market;
  • A progressive reward and benefits strategy, including enhanced family leave, healthcare, pension provision and location-relevant benefits;
  • Financial wellbeing support, including pension and financial education sessions; and
  • Transparent internal mobility — roles advertised internally, with structured performance and career conversations so progression is visible and fair.

5.3 Engagement

We invest in our employees’ growth, wellbeing and connection to community:

  • A structured listening cadence, anchored by our annual engagement survey and visible “you said, we did” follow-through;
  • We are introducing a programme of social impact activities, including opportunities for our people to volunteer;
  • We are introducing an annual charity partner selected by employee vote, supported by fundraising events and matching of employee donations up to a per-person cap;
  • Wellbeing programmes, including access to employee assistance support, we are introducing Mental Health Awareness Week activities; and
  • We are launching Employee Resource Groups that give employees voice and community.

5.4 Diversity

We are building an inclusive organisation where everyone can thrive:

  • Promoting diversity, equity and inclusion across the employee lifecycle;
  • Inclusive, structured hiring — competency-based interviewing and consistent selection standards to reduce bias; and
  • Establishing and tracking a Diversity Equity and Inclusion data baseline through our HR system, including gender representation and pay data.

6. Governance and Reporting

  • CSR objectives are monitored and overseen by the Senior Leadership Team, with day-to-day ownership held by the VP, People & Culture;
  • Introduction of key performance indicators to track environmental, social and governance impact, informed by external assessment (including EcoVadis);
  • Introduction of an annual Impact Report to provide transparency and accountability to stakeholders; and
  • Continuous review ensures alignment with legislation, investor requirements and best practice globally.

This policy forms part of our wider governance framework and should be read in conjunction with the Supplier Code of Conduct, Modern Slavery Statement, Code of Conduct, Whistleblowing Policy, and Information Security and Data Protection policies.

8. Commitment Statement

We are dedicated to building a sustainable, ethical and socially responsible business that benefits employees, customers, communities and the environment. By integrating CSR into every aspect of our operations, we aim to create long-term value and inspire confidence among our stakeholders.

9. Validity and Document Management

The owner of this document is the VP, People and Culture, who must check and, if necessary, update the document at least once every 12 months. When evaluating the effectiveness and adequacy of this document, the following criteria will be considered: changes in the law relating to CSR and ESG, changes in technology, changes to our business, and any areas of this policy that have proven to be unclear.

10. Contact and Queries

For further information or to provide feedback, please contact the People & Culture team at people@interactsoftware.com.

APPROVED & REVIEW

Simon Dance

Chief Executive Officer

Last reviewed: August 2026

Next review due: August 2027