Modern Slavery

Last updated: November 2026

1. Introduction

This interim Modern Slavery Statement covering the first half of the financial year ending 31 March 2027 is made by the OnStream Group pursuant to section 54 of the Modern Slavery Act 2015 and constitutes the Group's first standalone statement following its separation from Macquarie Group.

For the financial year ending 31 March 2026, Onstream formed part of Macquarie's wider modern slavery reporting arrangements and was covered under the scope of the global Macquarie Group Limited 2026 Modern Slavery Statement. Following its divestment on 9 April 2026, OnStream established a standalone governance framework integrating modern slavery, human rights and responsible business conduct considerations into its risk management, supplier oversight and business decision-making processes. These policies and this framework form the basis of this Statement, covering the six-month period up to 30 September 2026, and OnStream's first period operating on a standalone basis.

OnStream is committed to conducting business responsibly and has zero tolerance for modern slavery, forced labour, child labour, human trafficking or other serious human rights abuses within its operations, workforce, contractors or supply chain.

2. Our Organisation

This Statement covers OnStream Holdings Limited(company number 09794737), MM Holdings 2 Limited (company number 16642136) and their respective subsidiaries, including OnStream Meters Limited (company number 05867292), OnStream Group Limited (company number 08253776), OnStream Europe Limited (company number 16629068) and MM6 Limited (company number SC554085), together referred to as OnStream Group or the Group.

OnStream is a specialist meter asset provider operating primarily in the United Kingdom and Germany. The Group owns and funds metering assets and associated infrastructure but does not undertake meter installation or maintenance activities.

The Group employs approximately 65 people in the UK and Germany and also engages a small number of agency workers, contractors and professional consultants.

3. Our Supply Chain

OnStream's supply chain includes:

  • meter manufacturers and asset suppliers;

  • communications, technology and data providers;

  • logistics and transportation providers;

  • recycling and waste management providers;

  • recruitment and temporary labour providers;

  • professional advisers;

  • financial, insurance and software providers.

The Group acquires assets from a range of established metering manufacturers operating across multiple jurisdictions. Certain products purchased and owned by OnStream contain manufacturing or component supply chains linked to countries which are considered higher risk, including China, India, Vietnam, Egypt and Malaysia.

4. Modern Slavery Risk

OnStream considers modern slavery risk to be greatest within indirect supply chains rather than within its direct operations.

The principal areas of risk are:

Upstream Manufacturing Supply Chains

Potential exposure may arise through:

  • electronics manufacturing;

  • component suppliers;

  • subcontracted production;

  • raw materials and mineral supply chains.

Agency Labour

The Group utilises a limited number of agency workers within warehouse operations in the UK through established recruitment providers.

Logistics and Recycling Providers

The transportation, logistics and recycling sectors are recognised as presenting higher labour exploitation risks than professional services sectors.

OnStream assesses the risk of modern slavery within its direct workforce and office based operations as low.

5. Governance

Modern slavery risk forms part of OnStream's wider enterprise risk management framework.

The Group's governance framework includes:

  • Risk Management Framework, including annual risk assessment processes;

  • Supplier policy;

  • Whistleblowing Policy;

  • Anti-Bribery and Corruption Policy;

  • Quarterly Risk Committee oversight.

The Risk Management Framework specifically recognises modern slavery, labour exploitation and adverse human rights impacts as risks requiring identification, assessment and management.

6. Due Diligence

During the first six months of FY27, up to 30 September 2026, OnStream maintained supplier review processes and continued technical due diligence of the asset classes it purchases and owns.

For certain manufacturers, OnStream undertakes site visits to assess technical capability, manufacturing processes and operational resilience. These visits are not currently designed as labour-rights audits.

Due diligence is conducted using a risk-based approach which considers factors including supplier location, industry sector, use of subcontracting arrangements, labour practices and adverse media findings.

OnStream requires suppliers to comply with applicable labour and employment laws and to prohibit forced labour, child labour, human trafficking and other forms of labour exploitation within their own operations and supply chains.

Supplier governance measures include:

  • supplier screening;

  • sanctions screening;

  • adverse media reviews;

  • maintenance of a supplier register;

  • periodic supplier review requirements;

  • consideration of environmental and social risks within supplier governance activities;

  • OnStream has incorporated modern slavery provisions into relevant contracts as part of its supplier governance and contractual risk management approach since 2020.

7. Effectiveness

During the first six months of FY27, up to 30 September 2026:

  • all new suppliers within the scope of OnStream's supplier onboarding requirements were subject to the applicable onboarding procedures;

  • no actual or alleged modern slavery incidents were identified within OnStream's operations or known supply chain;

  • no concerns requiring remediation were escalated through established governance channels.

8. Training

OnStream recognises that workforce awareness is a key component of an effective Modern Slavery programme.

Modern Slavery training has been incorporated into the Group's Risk Management Framework and has been rolled out as mandatory training for relevant personnel.

9. Looking Forward

By the end of FY27, OnStream intends to strengthen its approach by:

  • implementing modern slavery and human rights questionnaires for higher-risk suppliers;

  • obtaining supplier attestations regarding labour and human rights standards;

  • continuing to incorporate modern slavery provisions into relevant contracts going forward;

  • undertaking annual reviews of higher-risk suppliers;

  • performing enhanced desktop due diligence where elevated risks are identified;

  • reviewing OEM labour, human rights and supply chain disclosures on a periodic basis;

  • delivering annual modern slavery training to relevant staff.

The Group will continue to develop a proportionate, risk-based approach reflecting its business model, operating footprint and supply chain profile.

10. Approval

This interim Statement was approved by the Board of Directors of OnStream Holdings Limited and MM Holdings 2 Limited on 3 November 2026.

Signed:

Ashley Phillips

Chief Executive Officer

For and on behalf of the OnStream Group