Modern Slavery and Human Trafficking Statement for the Financial Year Ending 31 December 2025

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (the “Act”) and sets out the steps that Sulmara Subsea International Limited and its direct and indirect subsidiaries ("Sulmara”) has taken during the financial year ending 31 December 2025 to prevent slavery and human trafficking in its business and supply chains.

Introduction

Sulmara is committed to acting ethically and with integrity in all business dealings and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place within its operations or supply chain and will never knowingly support or transact with any business involved in slavery or human trafficking.

Our Business

Sulmara continues to operate as an international provider of subsea and offshore support services. The size and structure of the organisation remain consistent with prior years, and the nature of our services, which depends on a highly skilled employment pool, continues to present a low inherent risk of modern slavery within our direct workforce.

Our Supply Chains

Our supply chain includes suppliers across multiple jurisdictions supporting offshore operations. Whilst the overall risk remains low based on the typical profile and skillsets of our suppliers, we recognise that certain geographic regions and service categories may present elevated risk.

We continue to communicate our expectations clearly to suppliers and require adherence to standards aligned with the Act and continue to maintain a zero-tolerance approach to modern slavery.

Policies and Commitments

Sulmara maintains:

  • An Anti-Slavery Policy; and
  • A Whistleblowing Policy to encourage reporting of concerns, supported by a non-retaliation commitment.

These policies remained unchanged in substance during 2025 and continue to apply to employees, contractors and suppliers.

Due Diligence Processes

During 2025, Sulmara continued to apply a proportionate, risk-based approach to due diligence, including:

  • Ongoing supplier risk assessment and segmentation;
  • Written supplier confirmations of compliance;
  • Contractual provisions addressing modern slavery, where appropriate; and
  • Periodic review of onboarding and certification processes.

Sulmara did not identify any instances of modern slavery within its operations or supply chain during the reporting period.

Training and Awareness

Employee awareness of modern slavery risks continued to be supported through:

  • Induction training for new employees; and
  • Targeted guidance for personnel involved in procurement and supplier engagement.

Training content was reviewed to ensure continued relevance and proportionality.

Monitoring and Review

Sulmara continues to monitor its policies and procedures to ensure they remain appropriate for the scale and risk profile of the business. Given the low-risk nature of operations, enhancements remain focused on maintaining effective and proportionate controls rather than introducing complex systems.

Looking Forward

In 2026, Sulmara intends to:

  • Maintain its risk-based approach to supplier due diligence;
  • Keep policies under periodic review; and
  • Monitor developments in legislation and guidance to ensure ongoing compliance.

Board Approval

This statement was approved by the Board of Directors of Sulmara Subsea International Limited on 29 April 2026 and is signed on its behalf by:

Kevin McBarron
Director and Chief Executive Officer
29 April 2026