Adviser Services Holdings Limited (ASHL)

Modern Slavery Statement

Modern Slavery and Human Trafficking Statement 2026

Reporting Period: Financial Year Ending 31 December 2026

Approved By the Board: October 2026

Version: 2.0

Introduction

Adviser Services Holdings Limited ("ASHL") is committed to operating responsibly, ethically and with integrity in all aspects of our business. We have a zero-tolerance approach to modern slavery, forced labour, servitude, child labour and human trafficking.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and outlines the steps taken by ASHL and its group companies during the financial year ending 31 December 2026 to identify, assess and mitigate the risk of modern slavery within our business operations and supply chains.

We recognise that modern slavery remains a global issue affecting all sectors and industries. Whilst we consider the risk within our operations to be relatively low, we remain committed to maintaining effective systems, controls and oversight to prevent modern slavery and human trafficking from occurring within our organisation or supply chain.

Our Organisation

Adviser Services Holdings Limited is the holding company that includes:

• Adviser Services Holdings Limited
• Sense Network Limited
• Lyncombe Consultants Limited
• Beyond Wealth (Financial Management) Limited

(together the ASHL Group)

The ASHL Group operates exclusively within the United Kingdom and provides services including:

• Financial adviser authorisation and oversight;
• Regulatory compliance support;
• Financial processing and administration services;
• Provision of regulated financial advice;
• Wealth and investment support services;
• Corporate and business support services.

The ASHL Group employs a UK-based workforce and operates under UK employment, regulatory and legal frameworks.

For the reporting period, ASHL Group turnover was approximately £107 million.

Our Supply Chains

Our supply chain primarily consists of UK-based suppliers and service providers, including:

• Technology and software providers;
• Cloud-hosting and IT support providers;
• Professional services firms;
• Recruitment agencies;
• Facilities management providers;
• Cleaning and maintenance contractors;
• Telecommunications providers;
• Utility providers;
• Office equipment and stationery suppliers;
• Financial advisers and appointed representatives operating within our networks.

Whilst we assess the overall risk of modern slavery within our direct operations as low, we recognise that certain supplier categories may present elevated risks, particularly where contracted services involve lower-paid labour or subcontracted workforces.

Governance and Responsibility

Ultimate responsibility for modern slavery compliance rests with the Board of Directors.

Day-to-day oversight is supported by:

• Executive Leadership Team;
• Compliance Function;
• Human Resources Team;
• Procurement and Supplier Management Functions;
• Legal and Risk Management Functions.

The Board receives periodic updates regarding compliance, risk management and policy effectiveness.

Our Policies

We maintain a range of policies designed to support ethical business practices and prevent modern slavery risks, including:

• Anti-Slavery and Human Trafficking Policy;

• Whistleblowing Policy;

• Grievance Handling Policy; and

• Recruitment and Employment Policies;

• These policies are reviewed regularly to ensure they remain effective and reflect legal and regulatory developments.

Risk Assessment

We conduct ongoing assessments of potential modern slavery risks within our operations and supply chains.

During 2026, we assessed and identified no high-risk relationships requiring escalation during the reporting period.

Due Diligence and Supplier Management

As part of our supplier onboarding and oversight processes, we undertake proportionate due diligence measures which may include:

• Supplier risk assessments;
• Review of supplier policies and governance arrangements;
• Contractual commitments relating to modern slavery compliance;
• Consideration of supplier reputation and regulatory standing;
• Review of publicly available information where appropriate.

Where appropriate, supplier contracts include provisions requiring compliance with applicable anti-slavery legislation and permitting termination where serious non-compliance is identified.

We expect our suppliers to:

• Comply with applicable employment and human rights laws;
• Prohibit forced, compulsory or trafficked labour;
• Maintain ethical recruitment practices;
• Ensure workers are free to leave employment voluntarily;
• Operate effective grievance mechanisms.

Recruitment and Employment Practices

ASHL is committed to fair and lawful employment practices.

Controls implemented include:

• Right-to-work verification;
• Identity verification procedures;
• Formal employment contracts;
• Compliance with UK employment legislation;
• Fair recruitment and remuneration practices;
• Equal opportunities procedures.

We do not tolerate exploitative labour practices within our workforce.

Training and Awareness

Relevant employees receive training designed to raise awareness of:

• Modern slavery risks;
• Indicators of exploitation;
• Responsibilities under company policies;
• Appropriate escalation and reporting routes.

Modern slavery awareness forms part of our wider compliance and ethics framework.

During the reporting period, training and policy awareness activities were undertaken across relevant business areas.

Speaking Up and Reporting Concerns

We encourage employees, advisers, contractors and suppliers to raise concerns regarding suspected wrongdoing, including concerns relating to modern slavery, human trafficking or labour exploitation.

Concerns may be reported through:

• Line management channels;
• Human Resources;
• Compliance teams;
• The ASHL Group's Whistleblowing arrangements.

Reports may be made in confidence and will be investigated appropriately.

ASHL does not tolerate retaliation against individuals who raise concerns in good faith.

Board Approval

This Modern Slavery and Human Trafficking Statement was approved by the Board of Directors of Adviser Services Holdings Limited (and of each group company listed above) and signed on its behalf.

Michael Couzens
Chief Executive Officer
Adviser Services Holdings Limited

Date: 26/10/2026

Document Control

Document version: 2.0
Effective Date: 26/10/2026
Last Reviewed: 20/10/2026
Next Review Date: November 2027

Publication: This statement is published on the ASHL website in accordance with section 54 of the Modern Slavery Act 2015.