Modern Slavery Statement

Introduction and Commitment

Star Lizard Consulting Limited (“Star Lizard”, the “Company”, “we”) is committed to respecting and upholding the human rights and freedoms of all individuals and to preventing modern slavery, forced labour and human trafficking in our operations and supply chains. We do not tolerate any form of modern slavery, and we expect the same zero‑tolerance approach from our suppliers, contractors and business partners.

This statement outlines our ongoing commitment to identifying, preventing and addressing the risks of modern slavery within our business operations and supply chains.

This statement is made pursuant to the UK Modern Slavery Act 2015. It covers the financial period from 1 August 2024 to 31 July 2025 and has been approved by the board of directors of the Company.

About Star Lizard

Star Lizard is a specialist sports data analytics and betting consultancy company. We use information on every aspect of a sporting fixture to provide an unparalleled view of what is happening on, and off, the pitch. We combine cutting-edge analytics with our expertise and passion for sport to produce world leading match predictions which are then fed into Star Lizard’s bespoke platforms to enable us to execute high frequency bet orders around the clock.

Star Lizard is incorporated in England and Wales and has its headquarters in Camden, London. It has two subsidiaries, Star Lizard Consulting (Ireland) Limited and Star Lizard Consulting (New Zealand) Limited, and as at the date of this statement has offices in the UK, Ireland, New Zealand and Canada.

Our Supply Chain

Star Lizard’s primary operations are data analytics and consultancy services, which rely on the supply of sporting data, technology services, back-office resources and IT equipment.

We have undertaken a detailed analysis of our network of suppliers and the modern slavery risks relating to each of them, with a particular focus on those areas where modern slavery may have been an issue in wider society, such as certain back-office suppliers. We have also reviewed how new suppliers are selected and we have considered the due diligence and other checks carried out on new suppliers before contractual arrangements are entered into.

In relation to the Company’s existing material suppliers, the Company has determined that the suppliers within its supply chain who have the highest potential risk of modern slavery or ethical issues each have processes and measures in place to mitigate these risks, such as robust employee vetting processes, and each of them has published a modern slavery statement which covers the steps it takes in relation to modern slavery, human trafficking and other ethical issues.

Following this detailed review, we have concluded that our network of suppliers and the supply chains that deliver services to Star Lizard should be regarded as low risk from a modern slavery and human trafficking perspective.

Preventing Modern Slavery

In order to support our commitments set out in this statement, we have implemented the following policies and standards relevant to modern slavery and human rights:

– Ethical and Anti-Slavery Policy – this policy sets out the Company’s commitment to ethical and anti-slavery behaviour and practices and covers our commitment in relation to matters such as preventing child labour and forced labour as well as the key pillars that the Company has put in place to ensure a modern slavery-free business. This policy is stated to apply to all employees, contractors including full-time, part-time, fixed-term and temporary workers. Furthermore, it includes a statement by Star Lizard that we expect our suppliers to operate on the principles set out in the policy. The policy sets out the ramifications and repercussions of a failure to comply with its terms for employees, consultants and other workers but also clearly statements that we may terminate any commercial relationships with suppliers, contractors and business partners if they breach this policy and/or are found to have been involved in modern slavery.

– Whistleblowing Policy – our whistleblowing policy sets out a confidential and straightforward process for reporting concerns and suspected issues with regards to behaviour of the Company and individuals with the Company. The policy details the available reporting channels and protections afforded to whistleblowers.

– Anti‑Bribery Policy – Star Lizard recognises the link between corruption, bribery and the exploitation of individuals and is committed to detailed anti-bribery measures as set out in this policy.

In addition, Star Lizard has in place a comprehensive set of employment policies to ensure that its employees, contractors and other workers are treated with the utmost respect, including detailed grievance policies and procedures, a dignity at work policy, a working hours and lone working policy, an employee wellbeing policy and an extensive set of leave policies including for carers, compassionate and bereavement circumstances and maternity, paternity and adoption leave.

Onboarding New Suppliers

Star Lizard requires all new material suppliers to undergo detailed due diligence checks as a mandatory part of our supplier onboarding process. As part of this due diligence process, if any suppliers are identified as having any modern slavery, human trafficking or other ethical issues, we would conduct enhanced due diligence checks on them. In addition, if a proposed new supplier was located in a high-risk jurisdiction, we may also choose to conduct enhanced due diligence checks if we considered that there was a risk of modern slavery or ethical concerns.

If any issues or matters of concern arise during the onboarding of new suppliers, these are raised with the Chief Operating Officer of Star Lizard for consideration and determination.

Continuing Due Diligence on Existing Suppliers

Star Lizard monitors its existing suppliers for any modern slavery, human trafficking or ethical issues or concerns that may arise. This monitoring is conducted through the review of media reports in relation to the relevant supplier and through the monitoring of the services being provided by the relevant supplier, looking out for any red flags which might arise. If any concerns do arise, these are raised with the Chief Operating Officer of Star Lizard for consideration and determination.

In light of Star Lizard’s Ethical and Anti-Slavery Policy, the Company very carefully considers if any issues or concerns that arise should result in the termination of commercial arrangements with the relevant suppliers and implements such termination promptly where needed.

Training

The senior management of, and key procurement individuals within, Star Lizard are trained on the issues concerning modern slavery and human trafficking in order to help mitigate any risk that might arise in relation to our supply chain and network of suppliers.

Additional Steps for 2026

Star Lizard is committed to continually improving its approach to identifying, assessing and mitigating the risks associated with its suppliers and its supply network. In the next 12 months, we are proposing to undertake a full audit of our existing policies to determine where additional codes of conducts and/or policies could be introduced to ensure the prevention of modern slavery and human trafficking.

In addition, we are proposing to introduce regular, periodic checks in relation to modern slavery and/or ethical concerns for our existing suppliers, to sit alongside the periodic financial checks we carry out. We will also be introducing checks on new suppliers considered to be either (i) material to the Company or (ii) high risk, in each case to understand whether they have a modern slavery statement/policy, and if not present, we will consider whether this is something that should be requested or raised by the Company’s relationship manager as part of the negotiation process.

Oversight

The board of Star Lizard has overall accountability for the matters set out in this statement and for all matters concerning the business’s approach to preventing modern slavery and human trafficking. Day‑to‑day implementation of these matters is led by Star Lizard’s Legal Team with support from the team leaders for each Star Lizard department or team.

Board Approval and Signature

This statement was approved by the board of directors of Star Lizard Consulting Limited in January 2026.