For Financial Year 2025
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (the “Act”) and has been approved by the Board of Afentra plc (the “Board”).
This statement is made in respect of the financial year ending 31 December 2025 by Afentra plc and its relevant wholly owned subsidiary Afentra (Angola) Ltd.
Introduction
Afentra plc is an independent oil & gas exploration and production company listed on the London Stock Exchange AIM market, with its headquarters in the United Kingdom. Afentra (Angola) Ltd (a wholly owned subsidiary of Afentra plc) has a branch office and employees located in Luanda, Angola.
Afentra (Angola) Ltd holds equity interests in a number of onshore and offshore oil and gas licences in Angola as a joint venture partner with local Angolan and foreign entities.
Afentra plc and its subsidiaries (including Afentra (Angola) Ltd) (the “Group”) is committed to ensuring that modern slavery and human trafficking do not take place in any part of its business or supply chains and to compliance with the requirements of the Act in the conduct of its business. Given the nature of our business, with a focus on Angola, we recognise the potential exposure of the Group, its operations and supply chains to the risk of modern slavery and human trafficking and we include in our operations and procedures the assessment of this risk and steps to ensure to the extent possible that instances of modern slavery and human trafficking are not within our business or supply chain.
Policies and Standards
Afentra plc has a range of policies that are relevant to our obligations with respect to the risk of modern slavery within our business and we apply these policies.
Our Code of Conduct and Business Ethics and the underlying policies and procedures it refers to and incorporates (the “Code”) sets out the standards that we apply to the way we work. The Code is designed to promote integrity in the way we work with all of our stakeholders, such as our partners, suppliers, contractors, host governments and local communities in the countries in which we operate. The Code and its implementation provide our personnel, as well as third parties with whom we conduct business, with the framework required to conduct their day-to-day business in accordance with the standards set out in the Code.
The Code applies to all directors, officers and employees of the Company and its subsidiaries as well as consultants, seconded staff, agency staff, interns and any other individuals who are engaged in providing services to the Company (together, “Company Personnel“) and their compliance with the Code is mandatory.
We expect our joint venture partners, suppliers, agents and advisors (our business partners) to act in a manner consistent with the Code when engaging in activities linked to our business. While we do not require our business partners to implement the specific processes within the Code (unless required under contract), we encourage them to develop and adopt similar standards and controls within their own business systems.
The Code defines and explains modern slavery and sets out the high level principles we expect those subject to the Code to comply with, as follows:
“Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.
We recognise that the nature and context of our business and supply chain exposes Afentra to the potential risk of instances of modern slavery and human trafficking. We work to regularly assess the extent of this risk to our business and have taken steps to ensure that underage, forced or bonded labour have no place in Afentra’s business or supply chain. Our systems and controls ensure that the risk of modern slavery is minimised in our business or supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains and we expect the same high standards from all third parties with whom we do business, including our contractors, suppliers and other business partners.”
The Code address our commitment to respect and protect Human Rights, including within the workplace and labour market as follows:
“Afentra respects and promotes internationally recognised human rights as set out in the Universal Declaration of Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at work. We endeavour to lead by example, always demonstrating our values of being respectful, transparent and inclusive. When considering new investments, we review associated potential human rights issues and their relationship to our operations. Afentra is committed to protecting the human rights of people in countries where we are doing business and our published Human Rights Policy provides a clear description of our approach. Afentra prohibits the use of underage, forced or bonded labour. We respect fundamental labour rights and international legal standards, including those guaranteeing decent wages, regulated working hours, and freedom from harassment.“
The Code is supplemented by our Anti-Slavery and Human Trafficking Policy and our Whistleblowing Policy.
The Anti-Slavery and Human Trafficking Policy details the obligation we place on all Company Personnel to prevent, detect and report modern slavery in any part of our business or supply chains and to avoid any activity that might lead to, or suggest, a breach of the policy. The policy sets out the process to follow to report or raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier. It is mandatory to make a report either to our General Counsel, or in accordance with our Whistleblowing Policy if any Company Personnel believes or suspects a breach of the policy has occurred or may occur. The policy notes that where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to our suppliers to help them address coercive or exploitative work practices in their own business and supply chains. The policy requires that our zero-tolerance approach to modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced when appropriate thereafter.
Our Whistleblowing (or speaking up) Policy encourages Company Personnel to speak up if they become aware of information which relates to a range of matters including criminal activity and breach of our other internal policies and procedures, including our Code of Ethics and Business Integrity, which cover modern slavery and human trafficking. The policy makes clear that such activity or conduct could relate to a third party, such as a joint venture partner, supplier or service provider. The internal and external mechanisms for reporting such concerns are detailed in the policy, including access to a helpline operated by the charity Protect, and a confidential hotline to report concerns on an anonymous basis. The policy is overseen by the Company’s Audit Committee whose members are Non-Executive Directors.
Supply Chain
Given our geographic focus on Angola and our primary business location in the UK, our supply chain consists predominantly of UK and Angola based providers of goods and services. The persons responsible for supply chain management within our Business sit within the Chief Operating Officer’s team and report directly to him, and they are responsible for the tendering and award of contracts. Where required we engage UK and Angola legal counsel to provide input to and review of the terms of contracts which we award and/or enter into and the execution and administration of those contracts.
In 2025 our organisation formally opened its permanent office in Luanda, Angola which required us to tender for and award a number of contracts for the procurement of goods and services associated with our developing business in Angola, and this was done in line with the Code and our policies and procedures regarding modern slavery and human trafficking described in this Modern Slavery Act Statement.
As a joint venture partner in a number of oil and gas exploration and production joint venture operations where we are not the Operator, we communicate to the Operator through both formal contractual mechanisms and informally, what we expect from them in terms of appropriate processes and procedures for identifying, mitigating and removing modern slavery within their supply chains, as well as compliance with applicable laws and regulations that apply to our Group. We conduct annual joint venture audits of the Operator’s accounts and conduct of joint operations which provides an opportunity to scrutinise the Operator’s administration of the joint venture’s business, its contracting arrangements and supply chains. The contracts which govern our joint ventures contain certain mandatory requirements for contract tendering and transparency by the Operator to us a non-Operator, and we have the right to request access to most contracts entered into by the Operator on behalf of the joint venture.
Next Steps
In 2026 we will continue to review the processes and procedures that we have in place to assess their adequacy for ensuring our compliance with the Modern Slavery Act 2015, and on a practical level ensuring to the extent reasonably possible that we are able to identify and prevent the risk of modern slavery arising in our business and supply chains.
We recognise the importance of ensuring that our Company Personnel, our business partners and contractors are aware of the issues and risks associated with modern slavery and human trafficking and we will continue to demonstrate to them our commitment, and the role they play in delivering it, to ensure modern slavery and human trafficking are not within our business and supply chains.
We will consider the appropriateness of delivering specific training to Company Personnel on modern slavery, alongside our existing mandatory training on anti-bribery and corruption and money laundering.
As a developing and growing independent oil and gas company, we recognise that we can learn from our peers in terms of their approach to modern slavery and their supply chains and we will seek to understand what our peers are doing in this area.
We will consider including performance KPIs for our employees that directly address modern slavery.
As we assume the Operator role in a number of new joint ventures in 2026 we will ensure that we capture best practice in mitigating modern slavery risks in the governance and contracting of the joint ventures and their supply chains, including ensuring contract terms include appropriate audit and reporting provisions relating to modern slavery.
Confirmation Statement
This Modern Slavery Act Statement has been approved by the Board of Afentra plc on 6 May 2026 and by the Board of Afentra (Angola) Ltd ) in compliance with the UK Modern Slavery Act 2015.
Signed by Paul McDade
Chief Executive Officer, on behalf of the Board of Afentra plc
7 May 2026