Modern Slavery Act Statement

This Statement is made by Zweig Advisory (comprising Zweig Services and Asset Management GmbH and Zweig Cost Control & Risk Management Services EST., hereinafter collectively referred to as "Zweig Advisory," "we," "us," or "our") pursuant to section 54 of the UK Modern Slavery Act 2015 (the "MSA"). It also reflects our commitment to proactive human rights due diligence, aligned with the principles of the German Supply Chain Due Diligence Act (LkSG).

Commitment and Scope

Zweig Advisory maintains a zero-tolerance policy towards all forms of modern slavery, including forced labour, human trafficking, child labour, and exploitation. We are committed to upholding ethical and fair labour practices across our global operations and supply chains.

Legal Framework Acknowledgment: Our commitment is enforced globally and respects the strong legal frameworks established in our operating jurisdictions, including the robust standards of the EU/Germany and the comprehensive anti-trafficking legislation of the United Arab Emirates, such as Federal Law No. 51 of 2006 (and its amendments) and Federal Decree Law No. 33 of 2021 on the Regulation of Labour Relations, which explicitly prohibits forced labour.

This Statement covers the entire consolidated group structure, including both the German/EU and UAE Mainland entities.

1. Organisation Structure and Supply Chains

Zweig Advisory is an international professional advisory firm. As a professional services provider, our direct workforce risk is low, as employees are highly skilled and regulated. However, risk is present in the global supply chains for auxiliary services:

Auxiliary Service Risk: The elevated risk of modern slavery and exploitation is concentrated in globally high-risk sectors (such as cleaning, security, and facility management). This risk is inherent to these industries worldwide due to reliance on low-skilled and migrant labour. We apply enhanced scrutiny to these high-risk contracts across all jurisdictions, including those managed by our UAE entity.

Medium-Risk Areas: Procurement of IT hardware, office equipment, and outsourced technology services, which involve complex, multi-tiered global manufacturing chains with lower visibility.

2. Policies in Relation to Slavery and Human Trafficking

Our commitment is formalized through robust policies applicable across the entire organization and supply chain, adhering to the highest standards of the jurisdictions in which we operate:

Anti-Slavery Policy: Confirms our prohibition of modern slavery, forced labour, and child labour, extending to all employees, contractors, and partners.

Supplier Code of Conduct: Mandates that all suppliers adhere to strict labour standards, safe working conditions, fair wages, and protection against exploitation, fully compliant with local labour laws, including the UAE Labour Law.

Grievance and Reporting Mechanisms: We maintain a confidential "Whistleblowing" mechanism, accessible to internal and external parties (including workers in our supply chain), to report concerns, suspected breaches, or unethical behaviour without fear of reprisal. This is supplemented by awareness of national reporting mechanisms, such as the UAE's hotlines for labour complaints and human trafficking issues.

Recruitment: Our recruitment policy ensures rigorous verification of all employees' identity and legal right to work to prevent illegal employment and forced labour.

3. Due Diligence Processes

We apply a risk-based approach to due diligence, ensuring our processes align with the requirements of the MSA and the proactive risk management expectations of the LkSG:

Procurement Integration: Anti-slavery requirements are embedded into all Requests for Tender (RFT) and supplier pre-qualification documents. The final award of any contract considers social responsibility equally with commercial viability.

Supplier Evaluation: For high- and medium-risk suppliers, we mandate either the provision of their own public Modern Slavery Statements or the completion of comprehensive self-assessment questionnaires to evaluate their controls and practices.

Auditing and Contractual Control: For the highest risk suppliers (e.g., cleaning and security), we reserve the contractual right to conduct unannounced social audits against specific labour standards to verify compliance.

4. Risk Assessment, Prevention, and Mitigation

We operate a continuous risk management system to identify and mitigate risks, focusing on high-risk activities globally.

Contractual Warranties: Contracts with high- and medium-risk suppliers include explicit warranties that they and their supply chains have not been convicted of modern slavery offences and that they will immediately notify Zweig Advisory of any actual, potential, or perceived modern slavery in their operations.

Proactive Remediation (LkSG Principle): If non-compliance or exploitation is identified, Zweig Advisory prioritises working collaboratively with the supplier to investigate, implement corrective action plans, and remediate the negative impact on workers. Contract termination is viewed as a last resort, demonstrating our commitment to positive change.

Compliance with UAE Anti-Trafficking Strategy: Our policies support the UAE's national five-point strategy to fight human trafficking, which focuses on prevention, prosecution, punishment, protection, and the promotion of international cooperation.

5. Key Performance Indicators (KPIs) to Measure Effectiveness

We measure the effectiveness of our actions through outcome-focused KPIs, demonstrating progress in risk reduction:

Area of Measurement	Key Performance Indicator (Outcome)
Due Diligence Completion	Percentage of high-risk suppliers successfully completing the mandatory social audit or risk assessment during the reporting period.
Remediation Rate	Percentage of non-compliances identified during audits that were successfully closed out by the supplier, demonstrating progressive improvement in working practices.
Awareness	Results of annual testing demonstrating that 80% of Procurement and HR staff can correctly identify "red flags" and appropriate reporting procedures.
Contractual Control	Number of investigations successfully concluded following internal or external reports, leading to verifiable corrective actions.

6. Training and Capacity Building

We ensure that all relevant personnel are equipped to prevent, identify, and respond to modern slavery risks:

Mandatory All-Staff Training: All Zweig Advisory personnel receive mandatory annual training covering the various forms of modern slavery, recognizing the signs of exploitation, and the use of internal reporting channels.

Specialised Training: Employees in high-risk functions (Procurement, Supply Chain Management, and Human Resources) receive targeted, in-depth training focused on identifying "red flags" in contractor documentation, performing advanced due diligence, and managing contractual compliance.

Approval

This Statement has been approved by the Senior Management of Zweig Advisory for the financial year ended.

Signed:

Name: Margarita Zweig, Alexander Zweig

Titles: Managing Directors

Contact and Entities

For general inquiries regarding this Statement or our compliance efforts, please contact the Compliance Department.

Joint Legal Entities and Registered Addresses:

Entity	Registered Address	Primary Jurisdiction
Zweig Services and Asset Management GmbH	Potsdamer Straße 92, 10785 Berlin, Germany	EU/Germany
Zweig Cost Control & Risk Management Services EST.	Westburry Tower 1, Business Bay, Dubai | UAE	UAE Mainland

Compliance Email: compliance@zweigadvisory.com