Modern Slavery and Human Trafficking Statement, 8 October 2025

Modern Slavery and Human Trafficking Statement, 8 October 2025

Introduction

The OSTTRA Group Ltd. and its subsidiaries and affiliates (collectively “OSTTRA”) is committed to
ensuring that we – and our suppliers – operate in compliance with all applicable laws as well as in
accordance with the highest standards of ethical behaviour, as outlined in the OSTTRA Code of Conduct.

OSTTRA supports and respects the protection of internationally recognised human rights and
endeavours to make sure that we are not complicit in human rights abuses. Accordingly, we do not
tolerate modern slavery or human trafficking in our organisation or supply chain.

Our business

OSTTRA provides end-to-end services to ensure all post-trade activities are processed and optimised
seamlessly, offering outstanding connectivity, innovative solutions and an unrivalled depth of expertise across capital markets workflows. We bring together four businesses that have been at the heart of post trade evolution and innovation for more than 25 years: MarkitServ, Traiana, TriOptima & Reset.

1,400 Post Trade Professionals, 8 Global Office Locations

Together, we play a critical role in supporting global financial markets, connecting thousands of
counterparties on our multi-asset networks that underpin the post trade lifecycle from trade capture, through portfolio optimisation, to clearing and settlement.

Organisational structure

OSTTRA Group Ltd is a UK tax domiciled company incorporated in Bermuda, headquartered in London,
with approximately 1500 employees in 11 countries worldwide.

Our supply chain

OSTTRA’s supply chain largely consists of professional services providers such as consultants,
accountants, law firms, contractors, software services, and data and content providers. OSTTRA also uses suppliers of IT, office equipment, facilities management, print production and publication distribution services.

Given the nature of OSTTRA’s business, we believe there is minimal risk of practices that support,
facilitate or are complicit with modern slavery, within either OSTTRA or our supply chain. Generally, we procure computer equipment as well as office supplies, equipment and services for the daily running of our businesses. In addition, from time to time, we use third party vendors and contractors for technology support and development, and for various advisory services. OSTTRA does not manufacture or sell any physical goods and, therefore, we have no supply chain relating to such activities. Nevertheless, we require that all vendors with whom we have a master services agreement agree to perform at the highest level of business and professional ethics, and to ensure that they and their subcontractors comply with all applicable anti-slavery and human trafficking laws, including but not limited to the UK Modern Slavery Act. We have also embedded these expectations in our purchase order forms and new vendor onboarding forms.

OSTTRA policies on slavery and human trafficking

OSTTRA has a zero-tolerance approach to modern slavery and human trafficking, which is confirmed in many of our corporate policies and procedures, including the Codes of Conduct and Third Party Provider policies. These documents articulate our commitment to respecting and promoting fundamental human rights, which we view as a key component of responsible corporate citizenship. In addition to supporting the fundamental principles contained in the United Nations Universal Declaration of Human Rights, we are committed to working with suppliers to help uphold ethical human rights standards.

Due diligence and further steps

OSTTRA has determined that the majority of its suppliers operate in areas considered to be at a low risk of supporting or being complicit in forced labour or human trafficking.

OSTTRA has implemented procedures to assess the risk of new vendors at onboarding and we require
suppliers to affirm their commitment to eradicating modern slavery and human trafficking.

OSTTRA monitors its business for potential risks related to slavery and human trafficking and other best practices adopted in our industry.

Reporting of Violations of the Slavery or Human Trafficking

We provide the means (including anonymous helplines) for employees and other third parties to make
confidential reports, raise complaints and request guidance about compliance or ethical issues, including matters referred to in our policies. These helplines provide another avenue through which we can ensure that any potential slavery, human trafficking or wider human rights impacts are identified and dealt with appropriately in our organisation. Each report of suspected misconduct is investigated by appropriate groups within our organisation and where a violation of policy is substantiated, corrective action is taken.

Training

To maintain awareness and ensure a high level of understanding of the risks of modern slavery and
human trafficking in our business, all employees have been made aware of this statement and reminders will be issued on an annual basis.

 

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This statement is made pursuant to section 54(1) of the Modern Slavery Act of 2015 and constitutes the slavery and human trafficking statement from 7th October 2025 for OSTTRA Group Ltd. and subsidiaries to which the Act applies. Signed on the Board’s behalf by:

 

John Stewart
Co-CEO and Chief Operating Officer

Services