Modern Slavery and Human Trafficking Statement

Modern Slavery and Human Trafficking Statement

Praedium Consulting Malta Limited and Mine Action and Training Mondial Kosovo Sh.p.K. (the PCM Group)

29 September 2026

This statement sets out the steps the PCM Group has taken, and is taking, to prevent modern slavery and human trafficking in its business and supply chains. The PCM Group is not currently required to publish a statement under section 54 of the UK Modern Slavery Act 2015; we publish this one voluntarily because we expect the same standards of ourselves and our suppliers in all of our work.

1. Our organisation and supply chains

Praedium Consulting Malta Limited (PCM), registered in Malta (C71922), designs and delivers explosive ordnance disposal (EOD), improvised explosive device disposal (IEDD) and humanitarian mine action training and advisory services for governments, international organisations and commercial clients. Its wholly owned subsidiary Mine Action and Training Mondial Kosovo Sh.p.K. (MAT Kosovo), registered in Kosovo (810745705), operates our training facility in Peja, Kosovo. We also deliver training and assessments in client countries, including in the Middle East and Ukraine.

Our supply chain is short. Its main elements are: qualified instructors and technical interpreters, employed by MAT Kosovo; a licensed demolitions range operator in Montenegro; accommodation, transport, travel and training consumables; and a small number of individual consultants.

2. Our policies

• Trafficking in Persons Compliance Plan (version 1.0, adopted by the boards of PCM and MAT Kosovo on 29 September 2026). It prohibits trafficking, forced labour, the procurement of commercial sex, the withholding of identity documents, deceptive recruitment, recruitment fees and sub-standard housing, and sets out how we prevent, detect and respond to them.
• Code of Ethics and Professional Conduct, which applies to all staff of PCM and MAT Kosovo.
• Anti-Bribery and Corruption Policy (version 1.1, 28 August 2026), which includes our whistleblowing arrangements and a commitment that nobody will suffer retaliation for raising a concern in good faith.

3. Due diligence and contracts

• We recruit directly and do not use recruitment agencies. We do not charge recruitment fees, and we do not pass on to workers the costs of visas, work or residence permits, medical checks or travel to the place of work.
• Workers receive written terms in a language they understand before they travel, keep their own identity documents, and are entitled to return travel at the end of their engagement. Where a passport must be held temporarily for a visa application, we do so only with the holder's written consent and against a receipt.
• Accommodation we provide or arrange for staff and trainees is checked against local housing and safety standards before first use and annually.
• Our contracts with suppliers and individual contractors include anti-trafficking obligations, which we require them to pass on to their own subcontractors, together with a right for us to terminate for breach. New counterparties are screened against applicable sanctions and exclusion lists before we contract with them.

4. Risk assessment

We consider our main risks to lie in: the short-term engagement of instructors and interpreters, including foreign nationals; accommodation we arrange for staff and trainees; trainees travelling to us from higher-risk countries; and purchases made in countries where we deliver training. Our controls focus on these areas. We will review this assessment annually and whenever we enter a new country or type of work.

5. Training and awareness

All staff and individual contractors of PCM and MAT Kosovo are being asked to sign a written acknowledgement of our anti-trafficking commitments and their whistleblowing rights, in English or Albanian, by 29 October 2026. Combined training on our Code of Conduct, Anti-Bribery and Corruption Policy and anti-trafficking commitments is scheduled for December 2026 and will be repeated annually. Instructors and interpreters receive a short briefing before each deployment.

6. Measuring effectiveness

We will report on the following in our next statement:

• the proportion of staff and individual contractors who have signed the acknowledgement and completed annual training;
• the proportion of supplier contracts containing our anti-trafficking clause;
• the number of accommodation checks completed; and
• the number of concerns reported, and how they were resolved.

Approval

This statement was approved by the board of directors of Praedium Consulting Malta Limited on 29 September 2026 and is published for the PCM Group. It will be reviewed and updated annually.

Benjamin Remfrey, MBE
Managing Director, Praedium Consulting Malta Limited
29 September 2026