Modern Slavery Statement

This Modern Slavery Statement is made pursuant to Section 54 of the Modern Slavery Act 2015. It outlines the steps taken by Penny on the Move—including Penny Petroleum Management Limited and all operating entities— to identify, prevent, and address risks of modern slavery and human trafficking within our operations and supply chains.

1. Our Business

Penny on the Move is a fuel and forecourt retailer operating approximately 100 sites across Northern England, North Wales, and Scotland. We directly employ around 1,000 colleagues across these locations. These operating regions have been assessed as low risk in relation to modern slavery and human trafficking.

2. Policies and Initiatives

We maintain a suite of internal policies to uphold legal compliance, ethical conduct, and a safe working environment. These include: • Bribery Policy • Code of Conduct • Equal Opportunities Policy • Grievance Policy and Harassment & Bullying Policy • Whistleblowing Policy All policies are reviewed at least annually and updated when legislation changes.

3. Risk Assessment

The risk of modern slavery within direct operations is assessed as low due to our direct employment model and stringent Right to Work processes. A higher risk exists within fuel supply chains, particularly where products originate outside the EEA. We work only with major global fuel brands and require supplier assurances on modern slavery compliance during contract establishment and renewal.

4. Due Diligence

Our due diligence processes include: • Mandatory Right to Work verification prior to commencement of employment • Secondary onboarding verification checks • Background and credit checks for leadership roles • Monitoring of immigration expiry dates • Annual Right to Work training for hiring managers • Paying all employees above the National Living Wage • Immediate investigation of any non-compliance with policy or employment law • Escalation of suspected modern slavery cases to the Senior Leadership Team and authorities

5. Training and Awareness

Modern Slavery Act Awareness Training is being delivered across the business. The Whistleblowing policy is signposted in all locations, and Right to Work training is mandatory annually for hiring managers.

6. Approval

This Modern Slavery Statement is approved by: David Penny Founder and Owner Penny on the Move Date: ____________________