Modern Slavery Statement

Kraken Group

Introduction

Kraken Technologies Limited (“Kraken”) is a private limited company with registration number 12014731, with various subsidiaries in the UK and globally. Kraken is the AI-powered operating system transforming utilities worldwide. Trusted by global leaders like EDF, E.ON Next, Octopus Energy, Origin, Plenitude, and Tokyo Gas, Kraken is contracted to manage over 70 million customer accounts, as well as the world’s largest virtual power plant of residential assets, and Europe's largest grid-scale battery. Our advanced data, AI, and machine learning automate much of the energy supply chain, delivering exceptional efficiency, faster innovation, and major cost savings on a cloud-based platform proven to scale across energy, water, and telco.

Group Structure

Kraken has various subsidiaries both in the UK and around the world. This statement applies to Kraken and all its subsidiaries, which are available at https://kraken.tech/kraken-group (together, the “Kraken Group”). Where one of our subsidiaries needs to take enhanced steps to ensure that modern slavery or human trafficking is not taking place in its supply chains or business (for example if it operates in a higher risk environment), we ensure that the subsidiary has appropriate measures in place, which may include a subsidiary producing its own modern slavery statement, if applicable.

Values

Kraken is passionate about creating a business which people want to be part of, as customers, partners and employees. We find the idea that people are forced to work against their will or best interests abhorrent and we’re committed to making sure this doesn’t happen across our supply chains in the Kraken group. We recruit brilliant people, we pay them fairly, and we treat them and their lives with respect, and we are methodical about ensuring that our suppliers and partners do the same.

Our People

Our people are the most important part of our group, and we are passionate about creating a business which people want to be part of. We have a particular focus on nurturing a culture of autonomy, empowerment and trust, and encouraging straight-forward, honest and transparent communication. We achieve this through a number of channels, such as informal, regular access to our senior management team, a fortnightly ‘Family Dinner’ where all members of staff across the world are invited to the same online meeting and encouraged to ask questions directly to the CEO and celebrate achievements together. We also monitor employee engagement through regular updates from the senior management team using data from various external tools

We offer a range of benefits and opportunities for our people. For example, all permanent staff own shares or are granted share options in the wider group, so derive added benefit from the ongoing growth and success of the business, helping to align employee values with those of shareholders.

We are also committed to offering equal opportunities, and we work hard to hire, promote and treat people on the basis of their merits and abilities. As an equal opportunity employer, we do not discriminate on the basis of any protected attribute, and we welcome applications for employment from anyone. Our commitment is to provide equal opportunities, an inclusive work environment, and fairness for everyone.

Suppliers

We carefully select partners and suppliers to work with based on a number of factors, including their reputation within their industry. We conduct risk assessments to identify and mitigate the risk of modern slavery and human trafficking within our operations and supply chains. This process involves evaluating the risk factors in various sectors and geographies where we operate.

Our onboarding process is clear on our business and personal principles, and where appropriate we include contractual provisions to reflect our suppliers’ responsibilities to minimise their risk of slavery and human trafficking.

Within our current product portfolio, we recognise that the risk of encountering modern slavery or human trafficking varies across different areas of our business and subsidiaries, with some sectors posing a higher risk than others. This is why we empower our people within these higher risk sectors to establish a responsible sourcing strategy aimed at mitigating the risks associated with their area of expertise.

We will not work with anyone who we believe is unable to keep to the standards we expect. We will not tolerate unethical behaviour by our suppliers in relation to slavery or human trafficking and we do everything we can to react promptly and effectively to any potential risks.

Due Diligence Process

Our due diligence processes are designed to manage the risks associated with third parties. Having assessed the relevant risk factors, our team creates a risk profile for potential new suppliers. Before onboarding, a due diligence review is conducted, covering areas such as information security policies, risk management practices, and business continuity plans. These processes are also intended to help identify and prevent the risk of modern slavery, human trafficking, and other unethical labour practices within our supply chain and business relationships.

To ensure accountability and transparency, we have established metrics to measure the effectiveness of potential new suppliers’ initiatives. These are measured with a RAG system and our team only moves forward with onboarding new suppliers if they are satisfied with the results. For suppliers with a higher risk profile, we may instruct an additional onsite audit through an independent third party to obtain more detailed information about the supplier.

Training

We provide our people with training on a range of compliance matters and our position on our approach to modern slavery and human trafficking risks is made available to our staff. Our training reinforces these values and equips employees to identify and respond to concerns. It’s important to us to make sure everyone - at every level of the business - is aware of our compliance requirements and the ways we can reduce identified risks.

Looking Ahead

Our due diligence processes are designed to effectively manage risks associated with third parties. After assessing relevant risk factors, our team develops a comprehensive risk profile for each potential supplier. Prior to onboarding, we conduct a thorough due diligence review, which includes evaluating information security policies, risk management practices, and business continuity plans. These processes are also intended to identify and mitigate the risk of modern slavery, human trafficking, and other unethical labour practices within our supply chain and business relationships.

We are committed both now and in the future to acting ethically and with integrity in all our business dealings. We regularly review our due diligence and procurement processes for working with new third parties, particularly as we enter new markets. Where we identify improvements that we consider will enhance our existing processes, we will look to implement these where appropriate, all whilst continuing to build our understanding and awareness of modern slavery and associated issues.

This statement is made pursuant to (i) Section 54(1) of the UK Modern Slavery Act 2015 and (ii) all other applicable laws relating to modern slavery and human trafficking pertaining to the Kraken Group. It was approved by the Kraken Board on October 24, 2025.