MODERN SLAVERY STATEMENT

This statement is made on behalf of Ace Games Technology Limited (“Ace” or the “Company”) pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes Ace’s slavery and human trafficking statement for the financial year ending 31 December 2023.

Ace has a zero-tolerance approach to modern slavery and human trafficking and will not trade or partner with any business or organisation, either remotely or indirectly, which breaches, or appears to be at risk of breaching the Act.

BUSINESS AND STRUCTURE

Ace publishes and distributes mobile games and has established relationships with globally renowned partners.

The Company is a private limited company and is incorporated and domiciled in London, UK. The games Company publishes and distributes are sold worldwide.

SUPPLY CHAINS

Ace’s supply chains include service providers, mobile games publishing and distributing services, application marketplaces, building maintenance services and marketing services.

Ace’s supply chain is not inherently exposed to traditionally high-risk areas of modern slavery.

APPROACH

Whilst there may not be a significant inherent risk of modern slavery in the supply chain, we strive to work to the highest professional standards and comply with all laws, regulations and rules relevant to our business. We are committed to addressing the risks of modern slavery in our operations and supply chains. Our policy on tackling modern slavery reflects our commitment to effective governance and ethical behaviour in all of our business practices.

RECRUITMENT

Our recruitment and employment procedures include appropriate pre-employment screening of all staff to determine right to work in the UK. We expect all employees to conduct business with honesty and integrity and we have a zero tolerance to bribery and corruption.

We are committed to the health and wellbeing of all our employees and ensure this through ethical practices in our operations as well as a strong HR support team.

We expect the same high standards from those we work with and are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

SUPPLIER DUE DILIGENCE

We work only with reputable service providers, many of whom are also subject to the Act. We require our supply chains to be transparent, accountable and able to demonstrate compliance with the provisions of the Modern Slavery Act 2015, either through their own Modern Slavery Statement, or through further questioning and contractual obligations.

We will terminate any contractual relationships immediately upon discovery of any breach of the Act.

FUTURE PLANS

We will continue to monitor, improve and review our policies and processes to ensure full compliance with the Act and to maintain best practice.

During 2023 we will focus particularly on the areas of employee education and supplier evaluation.

EMPLOYEE EDUCATION

We will continue to keep our employees informed and raise awareness of how to recognise and respond to indicators of human rights abuses. Where we identify additional training needs for our staff, we will ensure that they understand the implications of the modern slavery laws and can assist in implementing the requirements of the Act effectively.

SUPPLIER EVALUATION

We intend to commence an audit of our key suppliers and licensing partners within the next twelve months and will be introducing specific measures where relevant to ensure that our obligations under the Act are passed through our supply chain.