Modern Slavery and Human Trafficking Statement

RWS Modern Slavery and Human Trafficking Statement 2025/26 

RWS Holdings plc and its subsidiaries (“RWS”) are committed to understanding modern slavery risks and ensuring that our businesses and supply chain are free from modern slavery and human trafficking. This statement (made pursuant to section 54 of the Modern Slavery Act 2015 (the “Act”)) sets out the steps that RWS has taken during the financial year ended 30 September 2025 (“FY25”) and will continue to take to meet this commitment. We review this statement annually and this statement was approved by the Board on 4 November 2025. 

Like all businesses we run the risk of modern slavery within our operations including our supply chain. Due to the nature of our business, we feel that we carry a limited risk of modern slavery compared to other industries. However, we recognise our ongoing responsibility in managing our business and supply chains responsibly, to mitigate and where necessary remediate, the risks of modern slavery. 

There were no concerns or instances relating to modern slavery raised to us through our due diligence processes during FY25. 

Business and organizational structure 

RWS is a content solutions company, powered by technology and human expertise. We grow the value of ideas, data and content by making sure organizations are understood. Everywhere. 

Our proprietary technology, 45+ AI patents and human experts help organizations bring ideas to market faster, build deeper relationships across borders and cultures, and enter new markets with confidence - growing their business and connecting them to a world of opportunities. 

It is why over 80 of the world's top 100 brands trust RWS to drive innovation, inform decisions and shape brand experiences. 

With 60+ global locations, across five continents, our teams work with businesses across almost all industries. Innovating since 1958, RWS is headquartered in the UK and publicly listed on AIM, the London Stock Exchange regulated market (RWS.L). 

Policies and supply chain 

RWS has a number of policies and procedures designed to ensure that its activities, and those of its suppliers, are conducted ethically and in accordance with all applicable laws. These include the Modern Slavery and Human Trafficking policy, our Code of Conduct and policies and procedures relating to procurement and speaking-up. 

RWS has reviewed its supply chain to identify areas that may pose a higher risk of modern slavery and human trafficking. RWS’s key suppliers are entities or individuals providing professional services, primarily freelance workforce, who support RWS’s client-facing activities, as well as a range of suppliers providing other services to support the operation of RWS. We therefore believe that RWS’s supply chain continues to pose a lower risk of slavery and human trafficking than that of companies operating in other sectors; however, some risk does exist, and RWS is committed to mitigating that risk. By way of example, our programme for onboarding freelance workforce includes background and identity checks, mandated adherence to our Supplier Code of Conduct, training and ongoing monitoring. 

Employees 

RWS’s commitment to compliance with the Act applies equally to its own employees. Through its selection, recruitment and onboarding processes, RWS aims to ensure that the people it employs are not subject to modern slavery and human trafficking and are afforded the rights and protections that they are entitled to by law. 

We have implemented training programmes to raise awareness of ethical risks and to support full understanding and effective use of the Code of Conduct, which all colleagues are required to complete annually to ensure that employees are empowered to make the right decisions. 

RWS encourages employees to report concerns they may have about RWS’s compliance with applicable laws and/or breaches of its own ethical standards, including our Code of Conduct, without fear of retaliation. 

Risk Management 

In FY25 we partnered with EcoVadis and asked our top suppliers by emissions to complete the EcoVadis sustainability assessment. This assessment covers ESG performance including environmental management, carbon emissions, human rights, labor rights and health and safety. In addition, the reporting suite allows our Procurement team to see a range of supplier performance KPIs covering a huge amount of key information, including for example, whether the vendor has a Modern Slavery Statement and/or an Anti-Bribery & Corruption Policy. 

We also use this process in onboarding significant new 3rd party suppliers into our supply chain. 

Due Diligence 

Our standard terms and conditions include a clause that all suppliers are required to comply with our Supplier Code of Conduct under which Suppliers are expected to uphold the highest standards of human and labor rights. We have a zero-tolerance approach for any breaches against this policy and may terminate any agreement if there are any breaches or suppliers cannot demonstrate compliance with RWS policies. 

We continue to invest in third party systems and tools that provide strong identity verification. Proprietary solutions have also been implemented, increasing RWS’ ability to separate legitimate suppliers from illegitimate actors quickly and effectively. 

We have a detailed onboarding process for all suppliers ensuring compliance to key areas such as but not limited to: 

  • Fraud Mitigation 
  • Anti bribery 
  • Human Trafficking and modern slavery 
  • Data Privacy 
  • Environmental compliance

FY25 Progress and Effectiveness 

We continue to review our policies and practices to ensure our response to modern slavery remains effective, and during FY25 we continued the use of EcoVadis. 

During FY26 we will continue to review modern slavery, human rights and other ESG related criteria against our supply chain with the aim of strengthening our process to identify suppliers that may be at high risk of modern slavery. 

Governance 

This Statement has been approved for release by the RWS Board of Directors and made available on our website www.rws.com 

Maria Schnell
Chief Language Officer
4 November 2025