Modern Slavery and Human Trafficking Statement

Introduction

This statement is made on behalf of Dare International Ltd and its subsidiaries (together,
the “Group” or “Dare”) pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”)
and sets out the steps that the Group has taken during the financial year ending 31
December 2025 to combat modern slavery and human trafficking in its business and supply
chains.

The Group recognises the importance of tackling modern slavery and human trafficking. It
is committed to taking appropriate steps to ensure that modern slavery and human
trafficking does not occur within any part of the Group’s business or any of its supply chains.

Business

Dare International Ltd is a private limited company incorporated in England and Wales, with
the Group’s head office in the United Kingdom. The Group’s primary business is commodities
derivatives trading, as well as trading in gas and power markets and renewable energy
certificates. The Group trades the assets of its active group companies, Dare Global Limited
(a private limited company incorporated in the Cayman Islands), Dare Power Ltd (a private
limited company incorporated in England and Wales), Dare Sustainable Solutions Limited
(a private limited company incorporated in England and Wales) and Dare US LLC (a limited
liability company incorporated in Delaware, United States of America), and realises trading
opportunities by applying new technologies and quantitative models on a variety of
financial markets.

In 2025, the Group also incorporated two new group companies, Dare Commodities
Trading Pte Limited (a private limited company incorporated in Singapore) and Dare
Liquidity Solutions Limited (a private limited company incorporated in England and Wales),
the businesses of which were either not active or were in their infancy during the financial
year ending 31 December 2025.

The Group employs over 200 professional employees in the United Kingdom and is
committed to the welfare of all staff, including in terms of pay, working hours, environment,
health and safety, and wellbeing. The Group does not tolerate violations of basic human
rights or employment practices, by or against any staff, or within its supply chain.
As a professional service provider, the Group does not consider its business to operate within
a key risk sector as its staff work in roles that are primarily office based and/or generally
require specialist qualifications. Therefore, the Group assesses the risk of modern slavery
and human trafficking within its business to be low.

Supply chains

Due to the nature of the Group's business, the Group has a relatively simple, low-risk supply
chain model. For a substantial part of the Group's business, the supply chain primarily
includes exchanges, trading venues, brokers, market data providers and industry
professionals, most of which are subject to industry regulations and do not conduct labour
intensive businesses. Where appropriate, Dare also conducts counterparty screening and
onboarding before entering into any business relationships, including checks of international
databases and information systems.

In relation to the business operated by Dare Sustainable Solutions Limited, Dare expects its
suppliers of energy attribute certificates (in particular, energy generators), which are
organisations mostly based in the UK or Europe, to share the Group’s commitment to
combatting modern slavery. Where Dare purchases certificates from other intermediaries,
rather than directly from suppliers, information available on official certificate registries
provides transparency regarding the original generator or supplier. In addition to
customary onboarding checks and reviews, Dare seeks contractual assurances from
suppliers confirming their compliance with slavery and human trafficking laws and
regulations.

In more limited volumes, Dare may trade in certificates for renewable energy produced in
higher-risk jurisdictions outside of the UK and Europe, predominantly Mexico, in which case
additional due diligence is conducted on such markets (including in relation to ESG issues)
to approve trading and assessments are made as to whether additional contractual
protections are required. Counterparties from these jurisdictions are also subject to
enhanced KYC and onboarding checks, including on an ongoing basis.

Dare International Ltd also engages other miscellaneous suppliers as necessary to maintain
the normal day-to-day operations of the Group’s business and to support its core business,
such as cleaners, caterers and maintenance workers. Technology and software suppliers
are also material to the Group’s business and the Group’s IT Security team undertakes
specialist due diligence in relation to all such prospective suppliers.

The Group considers these services to generally present a low risk of modern slavery and
human trafficking. However, the Group recognises the need to continue to work with its
suppliers to tackle modern slavery in their own supply chains.

Governance

The Legal and Compliance teams are responsible for the Group’s management of modern
slavery risks and the adequacy of controls, as overseen by the General Counsel and Head
of Compliance. The Compliance team is responsible for counterparty onboarding
procedures and due diligence, while the Legal team assesses any identified risks, including
as flagged during counterparty onboarding and on an incident-driven basis. Where
appropriate, risks are escalated to the General Counsel for review.

Relevant policies, training and due diligence

The Group has policies and training programs in place that underpin its commitment to
ensure that there is no modern slavery or human trafficking in its supply chain or in any part
of its business.

As part of the Group’s onboarding process, new employees must acknowledge that they
have read the Health and Safety Policy, which sets out the Group’s commitment and
approach to protecting the health and safety of its staff and all those affected by its business
activities. New staff members are also advised of the Dignity and Respect at Work Policy,
which supports the Group’s commitment to a positive, diverse and inclusive work
environment in which bullying, harassment and discrimination are not tolerated.

New employees and professional contractors are also required to attend an induction in
relation to Dare’s Compliance Handbook, which makes it clear that the Group operates in
a highly regulated industry and that it is essential that the Group and its workers comply
with all legal and regulatory requirements.

The Compliance Handbook, which is distributed to all employees, also includes the Group’s
policies relating to:

• whistleblowing, which encourages employees to raise concerns about the Group, its
  business, other employees and counterparties, including suspected modern slavery
  incidents; and
• anti-money laundering and Know Your Customer checks with respect to counterparties.

Current copies of all policies are accessible to all workers via the Group's intranet platforms
and are subject to frequent reviews and updates. Further, Dare has rolled out additional
employee training to promote and support such policies, including mandatory sexual
harassment training and training on anti-money laundering and KYC in Dare’s business lines
(including additional, tailored training for the business undertaken by Dare Sustainable
Solutions Limited).

The Group also provides its employees with access to an employee assistance program
(provided by an independent third party company) that can be used by employees for free
and confidential advice in relation to workplace concerns or issues.

To assess the risks within its supply chain, the Group carries out diligence on its material
suppliers by making due enquiries of prospective suppliers, including in accordance with the
Compliance Manual and, in respect of IT or software vendors, a vendor risk assessment
questionnaire. The Group also adopts internal control and governance procedures with
respect to approving financial transactions and signing contracts with suppliers, ensuring
that contracts cannot be entered into without authorisation by a suitably senior and
qualified member of staff.

Looking ahead

The Group remains committed to maintaining strong policies and procedures to identify
and prevent modern slavery and human trafficking in its business and supply chains. It will
continue to review and enhance these policies and procedures over the course of the next
financial year.

Approval

This Statement has been reviewed and approved by the Board of Directors of Dare
International Ltd on 30 June 2026.

Ayman Rahman
Chief Executive Officer
Dare International Ltd