Modern Slavery Statement

1.1 Introduction

Humolli Capital is unequivocally committed to upholding the highest standards of ethical conduct, corporate responsibility, and human rights across all facets of our operations and investment activities. This Modern Slavery Statement is issued in accordance with applicable international best practices and reflects our ongoing efforts to prevent modern slavery, human trafficking, forced labour, and all forms of exploitation within our business and associated supply chains.

We recognise that modern slavery remains a pervasive global issue, affecting vulnerable populations across developed and developing economies. As a private equity and venture capital firm with strategic holdings across diverse sectors, Humolli Capital acknowledges both our moral obligation and our legal exposure in addressing these risks proactively and transparently.

1.2 Organisational Structure and Operations

Humolli Capital is a joint private equity and venture capital firm headquartered in Kosovo, with investment activities spanning early-stage enterprises, infrastructure development, energy transition projects, and public-private partnerships. While the nature of our core operations places us within a professional services context (where the direct risk of modern slavery is comparatively low) we maintain indirect exposure through the operations of our portfolio companies and extended supply chains, particularly in high-risk jurisdictions or sectors.

1.3 Our Approach to Modern Slavery Risk

Humolli Capital adopts a zero-tolerance stance toward all forms of modern slavery. We are committed to identifying, assessing, and mitigating risks of exploitation throughout our value chain. This commitment is embedded in our due diligence processes, investment screening criteria, and post-investment monitoring mechanisms.

As part of our fiduciary responsibility to investors and stakeholders, we integrate Environmental, Social, and Governance (ESG) considerations—of which human rights compliance is an integral component into all investment decisions and portfolio oversight functions. Where appropriate, we may require investee companies to adopt remedial action plans, implement third-party audits, or terminate relationships that fail to meet minimum ethical thresholds.

1.4 Governance, Policies and Controls

Our internal governance framework is underpinned by a suite of policies designed to ensure compliance with international labour and human rights standards, including:

• Responsible Investment Policy – Integrates human rights risk assessments into the investment lifecycle.

• Code of Conduct – Sets out clear expectations for ethical behaviour across all levels of the firm and its affiliates.

• Whistleblower Protection Policy – Establishes confidential channels for reporting unethical or unlawful conduct, with assurances of non-retaliation.

• Third-Party Due Diligence Protocols – Applied to suppliers, consultants, and other contractual counterparts.

We continue to enhance our compliance infrastructure through periodic reviews and alignment with emerging regulatory developments.

1.5 Training and Capacity Building

We are developing targeted training modules for investment professionals and portfolio managers to deepen awareness of modern slavery risks and compliance obligations. These efforts aim to equip our teams with the tools to identify red flags and respond appropriately within their respective areas of influence.

1.6 Continuous Improvement

Humolli Capital views the fight against modern slavery not as a one-time compliance task, but as an evolving area of strategic, legal, and ethical importance. In the year ahead, we intend to formalise a Supplier Code of Conduct, increase transparency in reporting, and explore alignment with global reporting frameworks such as the UN Global Compact and the Sustainable Development Goals.