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 2024 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 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.

The Group employs over 180 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 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.  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.  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.  As Dare continues to grow this part of its business, in addition to incident-driven assessments, Dare intends to monitor what further action may be necessary to monitor the risk of modern slavery in these supply chains. 

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.  

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.

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 Manual, 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 Manual, 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 is rolling out additional employee training to promote and support such policies, including mandatory sexual harassment training.  

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 4 June 2025.

Ayman Rahman
Chief Executive Officer
Dare International Limited