Modern Slavery and Human Trafficking Statement

1. Introduction

Odyssey Interactive Limited, trading as “Interact” (“we”, “us”, “our”), is committed to acting ethically and with integrity across all of our business activities. We have a zero-tolerance approach to slavery and human trafficking in all its forms.

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 ended 31 December 2025. It has been approved by our board of directors.

2. Our Organisation, Structure and Supply Chains

2.1 About Us

We are a software company incorporated in the United Kingdom. We develop and provide an internet-based intranet platform and ancillary services to organisations globally.

We employ approximately 250 people. Our registered office is in Manchester, United Kingdom, with colleagues engaged through an established employer-of-record arrangement in the Philippines and consultancy arrangements in Poland.

2.2 Our Supply Chains

As a software-as-a-service business, our supply chain is short, predominantly UK and EU based, and comprised principally of professional and technology services rather than manufactured goods. Our principal procurement categories are:

  • Cloud hosting and infrastructure services;
  • Software licences and technology subscriptions;
  • Professional services (legal, accounting, audit, consultancy, recruitment and employer-of-record services);
  • Office facilities and related services provided through managed, multi-tenant buildings (including cleaning, security and waste management, contracted by the landlord or managing agent);
  • IT hardware and office equipment; and
  • Marketing, events and travel services.

We consider the overall risk of modern slavery within our own operations and direct supply chain to be low, given the nature of our business, the skilled and directly employed character of our workforce and the jurisdictions in which we and the majority of our suppliers operate. We nevertheless recognise that no organisation is immune from risk, particularly in lower tiers of the supply chain, and we take proportionate steps to identify and mitigate it.

3. Our Policies in Relation to Slavery and Human Trafficking

We maintain internal policies and procedures designed to ensure we conduct business ethically and to help identify and address potential modern slavery risks. These include:

  • Code of Conduct: outlines the standards of behaviour expected of all directors, employees and those acting on our behalf. All new employees acknowledge the Code of Conduct during onboarding;
  • Supplier Code of Conduct: sets minimum ethical, social and environmental standards for suppliers, including express prohibitions on forced labour, child labour, the retention of workers’ identity documents, and worker-paid recruitment fees and requires compliance with the Modern Slavery Act 2015;
  • Whistleblowing Policy: provides confidential channels for staff and third parties to raise concerns about modern slavery or other unethical conduct. Individuals who raise concerns in good faith will not be subject to victimisation or any detrimental treatment;
  • Recruitment and right-to-work practices: all employees are engaged directly under written contracts of employment, with identity and right-to-work verification carried out prior to commencement of employment. We pay above the applicable national minimum and living wage in every jurisdiction in which we employ people; and
  • Grievance procedure: provides a formal, confidential route for employees to raise concerns about their treatment or working conditions, overseen by the People & Culture function.

Copies of our key policies are available to all employees via our intranet, and to suppliers and other stakeholders upon request.

4. Due Diligence Processes

We apply due diligence processes proportionate to the low-risk profile of our supply chain, including:

  • Contractual commitments: our supplier terms include provisions requiring compliance with applicable modern slavery legislation and our Supplier Code of Conduct, together with the right to terminate for material breach;
  • Supplier Code of Conduct roll-out: the Supplier Code of Conduct is being communicated to existing material suppliers and incorporated into new and renewed contracts;
  • Ongoing monitoring: reviews of existing suppliers, prioritised according to risk; and
  • Incident response: a process for receiving and responding to concerns or allegations of modern slavery through our whistleblowing channels, including escalation to senior management and where appropriate, remediation.

5. Risk Assessment and Management

We assess the risk of modern slavery in our operations and supply chains by reference to geography, sector and workforce vulnerability. Based on this assessment, the areas we consider as presenting the most significant potential risk, while remaining low in absolute terms, are:

  • Facilities services (cleaning, security and waste management) within the managed buildings from which we operate, where labour is engaged by third parties rather than directly by us;
  • The manufacture of IT hardware and electronic equipment, where risks sit deep in global supply chains; and
  • Outsourced and third-party labour arrangements, including employer-of-record and recruitment services, where we rely on established, reputable providers and retain direct oversight of working arrangements.

These areas receive proportionately greater attention in our supplier due diligence and in contract terms.

6. Training and Awareness

Relevant employees, including those in People & Culture, Finance and procurement-adjacent roles, are made aware of the requirements of the Modern Slavery Act 2015 and of the indicators of modern slavery.

7. Assessing and Improving Effectiveness

We assess the effectiveness of our actions to combat modern slavery through internal review of supplier engagement and due diligence outcomes, and analysis of concerns, incidents and whistleblowing reports and the outcomes of any investigations.

During the financial year ended 31 December 2025 we recorded:

  • Zero reported incidents, allegations or substantiated concerns relating to modern slavery or human trafficking within our operations or supply chains;
  • Zero referrals to the National Referral Mechanism or equivalent in any jurisdiction in which we operate; and
  • 100% of new employees onboarded during the period acknowledged our standards of conduct.

8. Board Approval and Sign-Off

This statement covers the financial year ended 31 December 2025 and has been approved by our board of directors. It will be reviewed and updated annually and published on our website, with a copy uploaded to the UK Government’s Modern Slavery Statement Registry.

SIGNED BY

Simon Dance

Chief Executive Officer

For and on behalf of the board of Odyssey Interactive Limited

Date approved: 12th August 2026