Statement on slavery and human trafficking

This statement is made pursuant to section 54(6) of the Modern Slavery Act 2015 and sets out the steps taken by Hastings Group (Consolidated) Limited (“HGC”) and its subsidiary entities (together the “Group” or “Hastings Group”) during the year ended 31 December 2025 to prevent modern slavery and human trafficking in our business and supply chains.

We recognise that no industry is immune from the risk of modern slavery and that effective action requires continuous improvement, transparency and collaboration.

This statement has been approved by the HGH Board, on behalf of the Group, on 28 April 2026.

Morten Thorsrud, Director, on behalf of Hastings Group (Consolidated) Limited and its subsidiary entities.

Our commitment

We have a zero‑tolerance approach to modern slavery and human trafficking. We are committed to acting responsibly and ethically in all our business relationships and to improving our practices to identify, prevent, mitigate and remediate risks in our operations and supply chains. We recognise that addressing modern slavery risk is an ongoing process and will continue to evolve our approach in line with emerging risks, guidance and best practice.

We also expect our suppliers, outsourced providers and business partners to uphold equivalent standards and cooperate with our due diligence and monitoring processes.

Structure, business and supply chain

Hastings Group is a provider of financial service products to the UK retail market, specifically for car, van, motorbike and home insurance and unsecured personal lending. The Group operates through three trading businesses:

Hastings Insurance Services Limited (“HISL”), trading as Hastings Direct, an insurance intermediary and service provider operating from three locations in the UK (Bexhill‑on‑Sea, Leicester and London).
Advantage Insurance Company Limited (“AICL”), an insurance underwriter based and regulated in Gibraltar.
Hastings Financial Services Limited (“HFSL”), an FCA‑regulated lending business.

HGC is the ultimate UK parent company of the Group and, via Hastings Group Holdings Limited (“HGH”), provides oversight of Group operations from its head office in Bexhill‑on‑Sea, East Sussex.

Our business model focuses on providing general insurance and other financial services products to customers in the UK only, via price comparison websites, over the telephone, and via digital platforms. The Group operates UK call centre operations for retail sales, customer service and claims handling functions, and has outsourced arrangements to supplement these operations in the UK and in South Africa.

We support, and remain committed to, the welfare of all of our colleagues in terms of pay, working hours, environment, health and safety, and wellbeing. We do not expect, and will not tolerate, violations of basic human rights or UK employment practices by any colleague, or within our supply chain. The number of colleagues directly employed by the Group as at 31 December 2025 was 4907. Our colleagues are engaged on a variety of full‑time, part‑time and flexible working arrangements and are appropriately remunerated, with pay set at levels exceeding applicable statutory minimum requirements and structured to support participation in workplace pension arrangements; the Group does not operate zero-hour contracts. Contractors are also employed by the Group from time to time, but these are generally professional workers for specific projects.

We foster a transparent and inclusive culture based on our 4Cs cultural framework ensuring the needs of Colleagues, Customers, Community, and Company shape how we operate. We take care to track and comply with all relevant UK employment legislation and follow ACAS best‑practice guidance in the design and operation of our formal colleague processes.

We listen and respond to issues and concerns our colleagues raise, either through formal surveys, colleague forums (including the Hastings Colleague Forum which we recognise for the purposes of statutory collective consultation), leadership escalation or, if necessary, direct engagement with the Chief Executive Officer. While the Group does not formally recognise a trade union, all colleagues have the right to be represented by a trade union member should they choose to do so.

HISL’s primary suppliers include price comparison websites, technology providers, outsourced call centre service providers, vehicle repair centres, car hire providers, and law firms, principally located in the UK, the European Union or the United States, with the exception of one outsourced operation based in South Africa.

AICL’s external supply relationships include reinsurance brokers, actuarial service providers, and reinsurers which, with the exception of some reinsurers, are all based in the UK.

HFSL’s primary suppliers include price comparison websites and outsourced technology platforms, all based in the UK.

No other Group company engages suppliers other than corporate, accounting and legal, professional, or advisory services sourced from UK based organisations.

We maintain visibility of our A* and A suppliers across key categories, and we recognise that visibility beyond these suppliers requires continued development, particularly within outsourced operation and vehicle repair networks. We will work with selected suppliers during 2026 to enhance understanding of recruitment practices and sub-contracting in higher‑risk areas.

Policies in relation to slavery and human trafficking

We have a responsibility to conduct business in an ethical and transparent way. Accordingly, we adhere to a set of business principles which include a commitment to respecting human rights and acting with integrity in all of our business activities.

Policies and procedures underpin our overall control and governance structure and support our 4Cs culture. These include policies covering conduct, whistleblowing, recruitment, anti‑bullying and harassment, health and safety, anti‑bribery and corruption, diversity and equality, compassionate leave, disciplinary matters, and religious holidays. These policies are reviewed and updated as appropriate to reflect changes in legislation, regulatory expectations and best practice. We also monitor how these policies operate in practice through reporting channels, supplier oversight and routine governance reviews.

In addition, we maintain a specific policy setting out our zero tolerance approach to all forms of sexual harassment in the workplace and our commitment to preventing such behaviour. This is supported by a dedicated online educational module for colleagues and an ongoing risk assessment process, through which key risk factors are identified, tracked and reviewed.

We have a procurement and supplier relationship management policy that supports our procurement and supplier management framework. This is designed to attract appropriate suppliers, secure value for money, manage risk, and ensure that relevant regulatory and legal obligations are met.

These policies and frameworks operate in practice through defined procurement controls, supplier onboarding requirements, contractual standards, mandatory colleague training, and ongoing governance and oversight processes. Together, they reflect our commitment to minimising the risk of modern slavery and human trafficking occurring anywhere in our business operations or supply chains.

Due diligence processes, risk assessment and management

We include appropriate measures in our due diligence processes to engage suppliers and business partners on a risk assessed basis. Supplier risk assessment considers factors including geography, sector, nature of services provided, use of subcontracted or temporary labour, and the extent of people based or onsite activity. As part of the procurement and supplier relationship management policy, we ensure that all suppliers undergo a stringent due diligence process before engagement, and continued oversight and performance management following engagement. Suppliers assessed as higher risk may be subject to enhanced due diligence, which can include additional questionnaires, contractual controls, and more frequent performance and risk reviews.

We do not treat an absence of identified cases as evidence of an absence of risk. Compliance with human rights, fair treatment and reasonable remuneration for employees, as well as safe working conditions, are all reviewed. Higher‑risk suppliers, including those operating off-shore or using sub-contracted labour, may be subject to enhanced due diligence.

As part of the pre-employment and recruitment process, we ensure that all colleagues are legally permitted to work within the UK and that they are joining us of their own free will and have not been coerced. HISL, AICL and HFSL are all regulated financial services firms, and background and financial checks are undertaken on all of our colleagues. We also require our suppliers to operate in a similar manner, where it is appropriate, in the context of the services they provide to the Group.

Training

We raise awareness of conduct, human rights and diversity and inclusion amongst our colleagues through annual mandatory training via an online platform. Colleagues in higher risk roles, including procurement, supplier management and relevant operational functions, receive additional role specific guidance proportionate to their responsibilities. Completion rates for all mandatory training are monitored and business leaders are informed when these rates are not satisfactory.

We also ensure all of our colleagues are aware of our whistleblowing policy, via our intranet and training modules, and all colleagues are given guidance on how to report potential or actual incidents confidentially. We encourage colleagues to report all potential or actual incidents that relate to wrongdoing or actual or suspected illegal or serious inappropriate activity, whether related to modern slavery or not. A confidential, externally facilitated portal is provided for colleagues to report their concerns, anonymously if they so choose.

Effectiveness

We do not treat an absence of identified cases as evidence that modern slavery risks do not exist.

We monitor any incidents of actual or suspected illegal or serious inappropriate activity and take action as appropriate.

During the year ended 31 December 2025 there were no identified incidents relating to modern slavery or violations of human rights within our business or supply chain.

To assess the effectiveness of our approach, we monitor training completion rates, supplier risk assessments, and the number, nature and themes of concerns raised through internal reporting channels. We track and analyse reported case types and trends over time in order to identify emerging risks and areas for improvement, and to inform the ongoing development of our prevention, due diligence and awareness‑raising activities.

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