Kepler Group EMEA Limited
‍November 30, 2023

The following statement is prepared in fulfillment of Kepler Group EMEA Limited and its applicable subsidiaries and affiliates (together, “Kepler EMEA”) obligations under the modern Slavery Act 2015. Kepler EMEA recognises that it has a responsibility to take a robust approach to slavery and human trafficking. Kepler EMEA does not tolerate any form of modern slavery or human trafficking in its business and corporate activities. References to ‘we’, ‘us’, or ‘our’ are to Kepler EMEA.

Structure of Organisation
Kepler EMEA is a digital media agency and consultancy that provides marketing, data analytics, and digital media planning services to clients in numerous sectors including retail, healthcare, and financial services. At the date of this statement, Kepler EMEA has offices in London and Singapore. The company is a member of Kyu Investment UK Limited, a strategic operating unit of Hakuhodo DY Holdings Inc.
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Supply chain
Given the nature of our digital business, Kepler EMEA’s supply chains are relatively simple and offer limited opportunities for modern slavery or human trafficking practices. However, compliance measures are in place to monitor this frequently within our business and supply chains. Our supply chain is principally made up of third-party media exchanges hosted in Europe and the US, global software and hosting providers in low-risk countries (in accordance with the Modern Slavery Index), and UK or US-based professional advisors.

Our Policies
Kepler EMEA’s internal policies include policies, which set out our ethical code on a number of matters, including Modern Slavery. These policies emphasise that we have a responsibility to do whatever we can to eradicate Modern Slavery in our business. All directors have been briefed on the subject of Modern Slavery and shall have overall responsibility for the implementation of the objectives in this statement.
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Due Diligence and Monitoring
As part of its initiative to identify and manage slavery and human trafficking risk, Kepler EMEA continues to implement the following measures:

• Establish and assess areas of potential risk in our business and supply chains

• Reduce the risk of slavery and human trafficking occurring in our business and supply chains through operational controls such as procurement policies and processes

• Engage with reputable suppliers who maintain similar commitments and processes to prevent modern slavery and human trafficking

• Abstain from entering into business and discontinue current business with any organisation that is found to be in breach of the Modern Slavery Act 2015.

Approvals
‍Our Board of Directors have approved this statement in November 2023.