Updated Mar 17, 2026 by Everplay
Legal · January 29, 2026
Published by Everplay
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.
so confidentiall Date of Statement:29 January 2026 everplay Modern Slavery Statement This statement is our response pursuant to Section 54 (1) of the Modern Slavery Act 2015 (the 'Act') and sets out the steps that everplay is taking to ensure slavery and human trafficking is not taking place in any part of our business nor in our supply chains. This statement covers all entities within the everplay group (the ‘Group’) required to comply with it including Team17 Digital limited and everplay Group Plc, as the legal parent entity.Th is statement covers the financial year ended 31 December 2025 and was approved by the Board of Directors on 29 January 2026. About Us everplay is a global games label, creative partner and developer of independent ("indie") premium video games, developer and publisher of educational entertainment ("edutainment") apps for children and a leading working simulation games developer and publisher. The business has nearly 370 employees in 5 locations/remote working under hybrid arrangements across the UK, Ireland, Germany, USA and Canada. Our Approach everplay does not tolerate any form of modern slavery or human trafficking in any part of our business. As a UK-centred video games developer and publisher computer gaming business, the Group has a relatively low risk of modern slavery within its employee base and relatively small supply chain. In addition to this statement, everplay has an Anti-slavery and human trafficking policy in place which is shared with all new employees/divisions that join the Group.
aming business, the Group has a relatively low risk of modern slavery within its employee base and relatively small supply chain. In addition to this statement, everplay has an Anti-slavery and human trafficking policy in place which is shared with all new employees/divisions that join the Group. Should anyone within our Group have any concerns and/or suspicions, including those that could be related to this subject matter; our Whistleblowing, Anti-Bribery and Grievance Policies also provide processes for employees to report on any concerning incidences which can be raised through either HR or contacting in written form or calling Safecall (the Group's external third-party hotline provider). Our Supply Chain The majority of our spend with external partners was made up of milestone payments to 3rd party development partners for new titles in development as well as royalty payments for completed and released titles. In addition to the 3rd party development partner payments, the Group utilises external work for hire companies that cover a range of activities covering game development, localisation and quality assurance testing as part of the overall game development process.
so confidentiall To continue our efforts, all new contracts and those renewing, will include a clause requiring that our suppliers, and their subcontractors, comply with the Act, and include the relevant company’s right to terminate in the instance of any breach of this obligation. Due Diligence everplay will make reasonable endeavours to ensure all employees and agents within our Group supply chain are not subject to any form of forced, compulsory/bonded labour or human trafficking by implementing this statement. This includes conducting reasonable levels of due diligence on new suppliers and employees to identify and manage any risks of modern slavery. Adequate resources will be made available to ensure slavery and human trafficking are not taking place within our organization or to the best of our knowledge within our supply chains. Risk Assessment As a game developer business, everplay does not have significant physical inputs into its business operations, but we understand that no supply chain is risk-free, and that greater risk may be present further down the supply chain. We continue to follow a risk- based approach to our supply chain. The majority of our supply chain retained a low risk of modern slavery however, a couple of areas were considered to carry a slightly higher risk which are QA testing and localisation, and we will continue to assess and manage the risks in these areas on an ongoing basis as part of the Group's overall risk register assessment review process which is carried out annually.
ver, a couple of areas were considered to carry a slightly higher risk which are QA testing and localisation, and we will continue to assess and manage the risks in these areas on an ongoing basis as part of the Group's overall risk register assessment review process which is carried out annually. Our risk assessment process has shown to be effective no reports of incidents of modern slavery have been received. The Group views this as a key metric in measuring its compliance with the Act. Additionally, we emphasize the importance of transparency and accountability. Therefore, our annual report, which includes the assessment of risks and our approach to support our internal teams and each of our stakeholders is published on our company's website. We believe that this regular reporting contributes to our commitment to combat modern slavery and ensure responsible practices throughout our businesses and supply chain. Governance Operational responsibility for reviewing our approach to modern slavery sits with our Audit Committee, which reports into the Board at least twice per year. For employees, suppliers, clients and third parties our whistleblowing policy encourages and enables reporting on anything of concern and explains how they can do
so confidentiall so confidentially. Concerns by employees can be raised through our HR teams or contacting our external third party provider in written form or calling directly. Awareness and Training We raise awareness among our employees, suppliers, and stakeholders of the risks of modern slavery and human trafficking, and the steps we are taking to prevent it. We are committed to providing necessary and appropriate training to all employees and suppliers to ensure that they understand their responsibilities effectively and how to appropriately identify and report any potential instances of modern slavery or human trafficking. We have adapted and re-promoted our existing corporate policies to address modern slavery and human trafficking where relevant, including our whistle blowing policy which allows employees to report any concerns confidentially. Our Commitment everplay continues to take positive steps to improve transparency within our divisions. The Board of Directors believe that the Group operates with a very low inherent risk of slavery and human trafficking potential. Nevertheless, this assessment is kept under continual review. The Board of Directors are responsible for the ongoing review of this statement as well as the Anti-Slavery and Human Trafficking Policy . This will be carried out annually or when any organisational changes arise that may impact the way the Group operates. Signed by: MikkelWeider Mikkel Weider everplay, Chief Executive Officer
sible for the ongoing review of this statement as well as the Anti-Slavery and Human Trafficking Policy . This will be carried out annually or when any organisational changes arise that may impact the way the Group operates. Signed by: MikkelWeider Mikkel Weider everplay, Chief Executive Officer 3 Red Hall Avenue Paragon Business Park Wakefield England WF1 2UL
Take-Two Interactive Software establishes a comprehensive framework for maintaining ethical business practices and safeguarding human rights across its global operations as of October 2025. The primary objective is to eliminate modern slavery, forced labor, and human trafficking within the organization and its extensive supply chains. This commitment extends across all major publishing labels, including Rockstar Games, 2K, Private Division, and Zynga, covering the development and distribution of interactive entertainment for console, PC, and mobile platforms. The policy outlines rigorous hiring and employment standards, mandating that all employees be at least 16 years of age and that employment is strictly voluntary. Compensation and benefits are reviewed annually to ensure they meet or exceed legal minimums and market standards. Furthermore, the company enforces a strict non-discrimination policy, ensuring that recruitment and career advancement are based solely on ability and merit rather than protected characteristics. These internal standards are reinforced by a Global Code of Business Conduct and Ethics that applies to all directors, officers, employees, and contractors. To ensure compliance throughout the supply chain, which includes disc replicators, printers, and logistics providers in regions such as North America, Europe, and Japan, the company utilizes a dedicated Supplier Code. This requires third-party partners to represent that they do not utilize child, prison, or slave labor. Oversight is maintained through biennial training for employees and targeted training for consultants. Additionally, the company provides a confidential reporting hotline managed by an independent third party, protecting whistleblowers from retaliation. Key suppliers are also expected to conduct periodic internal or independent audits to verify adherence to labor, health, and safety standards.
The 2019 corporate‑responsibility effort positions Modern Times Group (MTG) as a dedicated gaming and esports holding that integrates environmental, social and governance (ESG) considerations into its core strategy. By framing responsible practice as a source of competitive advantage for millennial and Gen Z audiences, the company seeks to mitigate material risks—discrimination, event security, exploitation of minors, corruption, occupational and mental‑health concerns, irresponsible marketing and gaming addiction—while driving profitability. A comprehensive materiality analysis informed a three‑tier priority pyramid that places health‑and‑well‑being and gender equality at its apex. Nine new group policies, including a Code of Conduct, whistle‑blower, anti‑bribery and data‑protection frameworks, achieved a 94 % employee
The Supplier Code of Conduct for Take-Two Interactive Software, Inc., updated in April 2023, establishes the ethical, legal, and professional standards required of all third-party partners. The primary thesis is that all suppliers, consultants, and vendors must mirror the company’s internal commitment to honesty, integrity, and human rights. This mandate extends globally to any entity providing goods or services, including distribution, marketing, and manufacturing, and requires these partners to ensure compliance among their own subcontractors and employees. The document outlines specific legal requirements across several critical domains. Suppliers must strictly adhere to competition and antitrust laws, anti-bribery and corruption statutes such as the US Foreign Corrupt Practices Act and the UK Bribery Act, and anti-money laundering regulations. Furthermore, the scope includes strict compliance with trade sanctions and export controls, specifically highlighting high-risk regions such as Iran, Cuba, Syria, North Korea, and certain areas of Ukraine. Partners are also prohibited from engaging in insider trading based on non-public information gained through their relationship with the company. Beyond legal compliance, the standards emphasize social responsibility and operational integrity. Key provisions include the prohibition of child or prison labor, the protection of fundamental human rights, and the maintenance of a work environment free from discrimination and harassment. Suppliers are required to maintain accurate financial records, protect intellectual property, and avoid conflicts of interest. To ensure adherence, the company reserves the right to conduct periodic audits and requires immediate notification of any legal investigations or violations. A global reporting infrastructure is provided, featuring a 24-hour ethics hotline available across more than twenty countries, supported by a non-retaliation policy for those reporting grievances in good faith.
The 2018 corporate‑responsibility overview for Modern Times Group (MTG) reflects a year of strategic realignment following the spin‑off of its Nordic Entertainment and Studios businesses into the newly listed Nordic Entertainment Group. The core thesis is that MTG’s renewed focus on esports, gaming and broader digital ventures can be pursued responsibly through four pillars—media responsibility, social impact, business ethics and environmental care—underpinned by materiality analyses for both entities and a suite of stakeholder‑driven priorities such as gender diversity, inclusion, GDPR compliance and the protection of minors. Financially, MTG reported net sales in the range of 15‑20 billion SEK and achieved an 89 % completion rate for mandatory ethics e‑learning. Risk management was strengthened by publishing event‑security guidance adopted by eight of twenty‑one partners, and by prioritising attendee safety at esports tournaments. Social contributions included a $18 k donation to UCSF, multi‑million‑dollar fundraising for Save the Children and the Diabetes Foundation, and the launch of education programmes targeting young gamers. Governance was reinforced through board oversight, external audits and memberships in more than a dozen industry bodies—including the IGDA, Esports Integrity Coalition and MESA—facilitating continuous stakeholder engagement via surveys, focus groups and board‑level dialogues. Environmental reporting showed a total carbon footprint of 25,215 t CO₂e, a 7 % year‑on‑year increase, while energy intensity fell sharply from 66 GJ per employee in 2016 to 40 GJ in 2018. Scope 3 emissions from events are now being captured, and no fines were recorded for direct energy use,