Modern Slavery and Human Trafficking Statement

GAC Group (GAC) is committed to conducting its business ethically and with integrity, ensuring that modern slavery, forced labour and human trafficking have no place in our operations or supply chains. We recognise our responsibility to prevent, detect and address risks of modern slavery wherever they may occur. This statement summarises our current approach to assess any potential risks relating to our business and the actions being taken to combat modern slavery.

Introduction

GAC Group (GAC) is committed to conducting its business ethically and with integrity, ensuring that modern slavery, forced labour and human trafficking have no place in our operations or supply chains. We recognise our responsibility to prevent, detect and address risks of modern slavery wherever they may occur.

This statement summarises our current approach to assess any potential risks relating to our business and the actions being taken to combat modern slavery.

Our Business and Structure

GAC is a global provider of integrated shipping, logistics and marine services operating in over 50 countries. Our services are delivered through a network of local companies serving customers across the energy, shipping, logistics and marine industries.

Policies and Governance

We have implemented a range of policies and procedures that reinforce our commitment to human rights and fair labour practices, including our:

  • Code of Ethics – setting clear expectations for ethical behaviour across all levels of the organisation;
  • Supplier Code of Conduct – requiring suppliers to uphold standards related to labour rights, working conditions and human dignity;
  • Compliance Policies – addressing the prevention of bribery, corruption, sanctions breaches and human rights abuses; and
  • Whistleblowing and Reporting Mechanisms – providing employees and third parties a number of secure ways to raise concerns confidentially, anonymously and without retaliation.

Risk Assessment and Due Diligence

We conduct ongoing assessments of our business and supply chains to identify areas with elevated risks of modern slavery or human rights violations. This includes the screening of suppliers and customers against international sanctions and adverse media.

GAC’s Whistleblowing Policy empowers all employees, including those working on behalf of GAC, to report any ethical concerns they may have regarding any aspect of our business without fear of reprisal. We have reporting systems and protections in place for whistleblowers and appropriate sanctions for non-compliance. By instigating these policies, GAC is using its influence to maximise its ability to combat all forms of modern slavery and human trafficking.

Training and Awareness

All employees are required to complete an e-learning course on our Compliance and Ethics Policies each year. The course defines our policies on fair treatment at work, ethical business conduct and compliance with legal requirements.

Wherever our operations are across the globe, all employees, including those working on behalf of GAC, contractors or supplier members of staff on GAC premises, are all held to the highest standard concerning respect for one another.

Monitoring and Continuous Improvement

GAC monitors the effectiveness of its approach through compliance audits, supplier assessments and feedback mechanisms. We are committed to continuous improvement and enhancing our processes as regulatory expectations and best practices evolve.

Approval and Review

To ensure a higher level of understanding of the risks of modern slavery and human trafficking, we will continue to review our processes and take action to maintain a zero-tolerance approach to modern slavery and human trafficking.

This statement is made pursuant to Section 54 (1) of the Modern Slavery Act 2015 and constitutes our Modern Slavery and Human Trafficking Statement for the financial year end December 2025.


Pontus Fredriksson
Group President
January 2026

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