2020 Corporate Responsibility Report

Everplay Modern Slavery Statement

Everplay maintains a zero-tolerance stance toward modern slavery and human trafficking across its global operations and supply chains. As a UK-centered video games developer and publisher, the organization identifies as having a relatively low inherent risk due to the nature of the digital entertainment industry. The operational scope covers the financial year ending December 31, 2025, and encompasses approximately 370 employees working across the United Kingdom, Ireland, Germany, the United States, and Canada. The primary supply chain expenditures involve milestone and royalty payments to third-party development partners, alongside work-for-hire contracts for game development, localization, and quality assurance testing. While the overall risk profile remains low, the organization identifies localization and quality assurance as areas carrying a slightly higher risk. To mitigate these concerns, all new and renewing contracts include mandatory compliance clauses regarding the Modern Slavery Act 2015, granting the company the right to terminate agreements in the event of a breach. Governance is managed through the Audit Committee, which reports to the Board of Directors at least twice annually. Due diligence efforts include a risk-based approach to supplier assessment and the implementation of internal policies such as whistleblowing, anti-bribery, and grievance procedures. Employees and third parties are provided with confidential reporting channels, including an external hotline. The effectiveness of these measures is tracked through an annual risk register assessment, which currently reports zero incidents of modern slavery. Training and awareness initiatives are provided to ensure that employees and stakeholders can identify and report potential risks effectively.