Modern Slavery and Human Trafficking Statement

For the Financial Year 2025–2026

Published in accordance with Section 54(1) of the UK Modern Slavery Act 2015

Introduction

At Snorkel Europe Ltd., we are committed to ensuring that modern slavery and human trafficking have no place in our business or supply chains. Modern slavery refers to the severe exploitation of individuals through coercion, control, or deception—including slavery, servitude, forced or compulsory labour, and human trafficking.

These crimes can occur in any country and industry, often hidden deep within supply chains. Snorkel Europe Ltd. takes a firm stance against these practices, recognising their devastating impact on individuals and communities. We are committed to continuous improvement in identifying, preventing, and mitigating the risk of modern slavery throughout our operations.

This statement outlines our approach during the financial year 2025–2026 to addressing these issues and reflects our ongoing commitment to ethical and responsible business practices.

Organisation and Supply Chains

Snorkel Europe Ltd. is a global manufacturer and distributor of aerial work platforms and powered access equipment. Headquartered in Nevada, USA. Our manufacturing operations are based in:

• Henderson, Nevada, USA
• St. Joseph, Missouri, USA
• Washington, United Kingdom
• Jintan, China

Our European headquarters, located in Washington, UK, employs approximately 160 people. We serve a global market through over 200 distribution and service locations worldwide. We maintain a global supply chain to source parts and components and are committed to working only with suppliers that align with our values of integrity, transparency, and human rights.

Definition

Snorkel Europe Ltd. defines modern slavery to include:

• human trafficking.
• forced work, through mental or physical threat.
• being owned or controlled by an employer through mental or physical abuse of the threat of abuse.
• being dehumanised, treated as a commodity or being bought or sold as property.

• being physically constrained or having restrictions placed on freedom of movement.

Our Commitment

Snorkel Europe Ltd. recognises its responsibility under the Modern Slavery Act 2015 and is committed to:

• Promoting a safe, respectful, and inclusive working environment
• Ensuring all employees can report concerns confidentially and without fear
• Reviewing internal practices and external supply chains regularly to assess and mitigate risks
• Never knowingly engaging with organisations involved in modern slavery or forced labour

We adhere to all relevant employment legislation and often exceed minimum requirements to support the well-being and rights of our employees.

Policies Supporting Our Approach

To ensure a zero-tolerance stance on modern slavery, we maintain the following internal policies and standards:

• HRP009 – Public Interest Disclosure (Whistleblowing Policy)
• HRP048 – Ethics and Conduct Policy
• HRP008 – Anti-Harassment and Bullying Policy

These policies are designed to create a transparent, ethical workplace culture and to ensure responsible sourcing and procurement practices.

Due Diligence and Supply Chain Management

As part of our initiative to identify and mitigate the risk of slavery and human trafficking occurring within our business and supply chains, the Company undertakes due diligence when taking on new suppliers and regularly reviews its existing ones.

Measuring Our Effectiveness

To measure the success of our efforts and drive continuous improvement, Snorkel Europe Ltd. uses the following performance indicators:

• Training: All employees in supply chain, purchasing, engineering, sales, product support, and HR will complete refresher training on modern slavery by 31 March 2026
• Supplier Verification System: A new system to evaluate prospective suppliers will be implemented by 31 December 2025
• Supplier Code of Conduct Compliance: All existing suppliers will be required to sign and return the Snorkel Supplier Code of Conduct by 31 December 2025

Training and Awareness

We believe awareness is critical in the fight against modern slavery. As part of our commitment:

• All relevant employees, including managers and professionals in supply chain, engineering, quality, and HR, must complete mandatory training on identifying and reporting modern slavery
• Refresher training is required to ensure continued understanding and vigilance

Governance and Review

This statement has been approved by Snorkel Europe Ltd.’s senior executive team and is reviewed annually to ensure ongoing compliance and effectiveness. We remain committed to strengthening our approach and acting decisively to prevent modern slavery in all areas of our business.

Approved by:
Charles Brooks
Regional President EMEA & CFO
Snorkel Europe Ltd.
Date: 26 June 2025