Compliance

J.D. Power Climate-Related Risk Report | TCFD & SB 261

J.D. Power’s climate-related financial risk and opportunity report aligned with TCFD recommendations and California SB 261 compliance requirements. Published November 2025.

Executive Summary

J.D. Power is a global leader in consumer insights, market research, data analytics, and advisory services. Our reputation is built on delivering trusted benchmarks, performance insights, and advisory solutions that empower clients to make data-driven decisions. We serve a wide range of industries, including automotive, financial services, insurance, healthcare, home improvement, technology, media and telecommunications, travel and hospitality, senior living, and utilities.

J.D. Power currently has operations in North America, Europe and Asia Pacific and is a privately held company within the Thoma Bravo portfolio.

J.D. Power recently expanded into sustainability-focused offerings through our Sustainability Index and the Certified Sustainability Leader Program, which supports the utility sector to advance customer engagement on climate programs. Additionally, with our acquisition of ZappyRide in 2023, we are positioned to deepen our role in supporting the automotive industry’s transition to electric vehicles. Additionally, within our Autovista business based in Europe, we have engaged in ESG-related reporting including through the EcoVadis platform.

This report marks our first formal assessment of climate-related risks and opportunities in North America by identifying our climate disclosures under California Senate Bill 261 (SB 261) and the Task Force on Climate Related Financial Disclosures (TCFD). Our disclosures reflect our current practices and establish a foundation for ongoing evolution in governance, strategy, risk management, and metrics.

Governance

Board Oversight of Climate-Related Risks and Opportunities

Our Board of Directors does not formally oversee climate-related risks, though at least on an annual basis, J.D. Power shares ESG-related information with Thoma Bravo. Additional Board oversight would be driven primarily by compliance requirements under California and other applicable climate regulations.

Management’s Role in Climate-Related Risks and Opportunities

Responsibility for climate-related disclosures for our North American business currently resides with our Corporate Legal Department, which has oversight for other related compliance matters. The Legal Department currently reports to our Chief Operating Officer and ultimately to the Board. Climate-related risks and opportunities are assessed in the context of regulatory compliance, supported by third parties engaged to assist with disclosure readiness. Climate considerations are not currently integrated into cross-functional decision-making across risk, finance, or operations.

Strategy

Climate-Related Risks and Opportunities Over the Short, Medium, and Long Term

We define short term as less than one year and medium term as 3–5 years for business planning and risk mitigation purposes. This disclosure represents our first structured evaluation as we have not historically monitored climate-related risks in our North American business.

Physical Risks

To complement our qualitative risk identification, we conducted a physical climate risk assessment using First Street Foundation’s risk modeling, under the SSP2 “Middle of the Road” scenario, across both current (2025) and long-term (2055, 30-year outlook) timeframes. Risks were evaluated for 1% annual probability (100-year event) across our physical footprint.

Physical risks do not present a widespread operational risk for our portfolio. Some properties face elevated risk of flooding, while properties across Central and Northern Europe registered a risk for operational disruptions from winter storms and freezing events. Drought exposure also emerges at higher levels in select sites, signaling possible long-term challenges around water availability and energy reliability. Other hazards such as wind, fire, and heat appear generally moderate in character, with no consistent pattern of high exposure. Overall, our portfolio’s leased office profile means building-level damage is less likely to be directly absorbed by the company, but operational continuity, access, and workforce safety remain core concerns. As a 95% remote workforce, our overall business model faces relatively limited direct exposure to acute or chronic physical risks. Our data centers have redundancy and business continuity plans in place.

Annual conferences represent another aspect of our business model. Physical interruptions to locations selected for these conferences may impact our business and require us to mitigate risk by transitioning to a remote hosting environment. Due to past weather-related disruptions affecting conferences, we have implemented contingency planning measures, including remote participation capabilities, and continue to evaluate locations to host future conferences and client events to mitigate potential disruption.

Transition Risks and Opportunities

Market Risks & Opportunities

Electric vehicles represent a market segment that we are well positioned to support. Our acquisition of ZappyRide strengthens our ability to serve electric auto manufacturers to a lower-carbon economy. Concurrently, we are noticing an increase of customer requests for emissions reporting and climate data, suggesting an evolving market expectation.

Alongside these developments, our Sustainability Index and Certified Sustainability Leader Program provide further opportunities to expand climate-related services and reinforce our role to support this market growth.

Policy & Legal Risks

The preparation of this TCFD-aligned report prepares us to meet SB 261 obligations and respond to future regulatory developments. In addition, we have a dedicated ESG

• resource in the United Kingdom, responsible for UK compliance obligations such as SECR.

Technology Risks

More sustainable cloud and server infrastructures may become a priority over the medium term in the event it becomes more cost-effective to pursue a renewable energy data center infrastructure.

Impact on Business Model and Resilience of Strategy

Climate-related risks and opportunities are integrated in our business where appropriate. For example, our acquisition of ZappyRide was influenced by climate transition opportunities in the EV sector, reflecting our strategic intent to expand services in this market. Similarly, our Sustainability Index and certification program represents active lines of business that generate climate-related insights and recognition for utility companies, reinforcing our position as a trusted provider of sustainability-related intelligence. Similarly, our insurance underwriting is influenced by the need to protect against physical climate-related risks when assessing property exposures in our broader risk and financial planning framework. Our insurance brokers provide catastrophe likelihood and modeling for physical events such as floods, fires, and earthquakes. We also maintain redundancy in our technology infrastructure and rely on insurance risk models and contingency planning to evaluate resilience.

Risk Management

Processes for Identifying and Assessing Climate-Related Risks

We respond to climate-related risks and opportunities as they arise, with primary emphasis on ensuring regulatory compliance. Legislative monitoring serves as the primary tool for identifying new climate obligations.

Processes for Managing Climate-Related Risks

Management of North American climate risk resides within our legal department by an annual compliance review led by Senior Counsel. We leverage insights from insurance

• providers regarding property-related risk exposures and maintain continuity planning for critical infrastructure.

Integration into Overall Risk Management

Current efforts for climate-related risks are compliance-driven, supported by insurance renewals and continuity planning.

Metrics & Targets

We currently report annual energy consumption through compliance with the UK’s SECR and ESOS frameworks. We have not set greenhouse gas (GHG) emissions targets or measured emissions beyond UK regulatory reporting requirements. Our focus remains on regulatory compliance and market-driven opportunities.

Cautionary Statement

NO PRESUMPTION OF MATERIALITY

This report has been prepared in accordance with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) to comply with California’s SB 261. It is intended to provide information regarding potential climate-related financial risks that the company may face. The risks and statements described herein are based on current knowledge, assumptions, and available data as of the date of publication.

Nothing in this document is intended to imply, nor should it be construed to indicate, that any specific risk or statement discussed is financially material to the company. The identification or discussion of any particular risk does not constitute an admission or representation regarding its materiality, probability, or potential impact under applicable securities laws or accounting standards. Readers are cautioned not to place undue reliance on forward-looking statements or scenario analyses, which are subject to inherent uncertainties.

The company undertakes no obligation to update any information contained in this report except as required by law.

The directors (the “Board”) of the Autovista Bidco Limited (the “Company”) have considered their duty under section 172 of the Companies Act 2006 to act in good faith and to promote the success of the Company for the benefit of its shareholders as a whole. In particular, the directors have had regard to:

• likely consequences of any decision in the long term;
• the interests of the Company’s employees;
• the need to foster the Company’s business relationships with suppliers, customers and others;
• the impact of the Company’s operations on the community and environment;
• the desirability of the Company maintaining a reputation for high standards of business conduct; and
• the need to act fairly as between shareholders of the Company.

This section of the report summarises the Group’s governance structure which covers the values and behaviours expected of its employees, how it engages with stakeholders and how the directors look to ensure that the Group makes decisions that drive long term value creation.

Decision making, values and governance

• During 2025:

  • board changes took place but the Board includes three highly experienced directors. Each member of the Board has a vast depth of experience from differing career backgrounds. Whilst there are certain matters that are reserved for the shareholders, the Board otherwise exercises day-to-day decision making through delegated authority to certain key employees. This authority is set out, and continually updated, in the Group’s internal authorisation framework.

  • The Company’s ultimate U.S. parent introduced:

    • a revised, enterprise-wide three-year growth strategy (“Strategy”); and
    • new organisational structure and company-wide values, focusing on customers, collaboration, innovation, accountability, data‑driven decision‑making, smooth workflows to simplify processes and trust (“Values”).

    In adopting and implementing the Strategy and Values, the Board carefully considered its relevance to the Group’s operations and how it supports the long‑term success and sustainability of the Group, while taking into account the interests of key stakeholders.

• In considering the Strategy, the Board focused on its long-term implications for the Group, including its financial resilience, competitive positioning and ability to generate sustainable value. The Strategy builds on the Group’s established strengths within the automotive industry while also providing a measured pathway for growth through new products, expanded customer relationships, and selective expansion into auto-adjacent industry markets. The Board considered that the Strategy’s emphasis on data integration and increased investment in innovation supports long-term operational efficiency, scalability and relevance to customers. Decisions relating to structural realignment and investment in technology and artificial intelligence were assessed against their expected long-term benefits, including improved decision making, enhanced customer offerings and the safeguarding of the Group’s future competitiveness. Another aspect of the Strategy includes the implementation of a revised organisational structure, and an emphasis on talent development and upskilling, designed to support employee engagement, retention and long-term capability building.
• The Values, which reflect feedback obtained through employee engagement initiatives, are intended to foster a positive, inclusive and high-performing culture across the Group. The Board places significant importance on maintaining the Group’s reputation for integrity, professionalism and high standards of business conduct. The emphasis within the Values on trust, integrity, accountability and acting in the best interests of customers, reinforces the Group’s long standing role as a trusted advisor within the automotive industry.
• The Board operates alongside various employees who are responsible for identifying, managing and reporting risk across the Group, ensuring compliance with policies, laws and regulations that govern the Group’s operating activities and supporting appropriate governance and decision-making. This also includes business continuity planning across the Group with the aim of ensuring the safety of employees and the continued ability to operate under adverse trading conditions, including a global pandemic, severe weather, virus threats and global conflicts. The risk framework includes a number of committees sanctioned by the Board as well as Group policies which help support s.172 requirements including the Anti-Slavery and Human Trafficking, Anti-Bribery, Anti-Facilitation of Tax Evasion and Whistleblowing policies. These policies are communicated to employees, available for reference and are further articulated through a series of training videos. The contents of these training sessions were reviewed in 2025, and it is mandatory for all employees to complete these training modules at certain intervals to ensure that knowledge of these important topics remains up to date. The Group Anti-Slavery statement is available on the Group’s website at:https://www.jdpower.com/business/regional-compliance/#modern-slavery.
• The Group’s Risk committee as well as the Business Compliance Committee met at least on a quarterly basis. These groups are comprised of senior members of the executive team and have delegated responsibility by the Board to review risks to the business from various areas including Bribery, Facilitation of Tax Evasion, Health and Safety and the controls in place to manage these risks.
• The Group maintains directors’ conflicts of interest registers for companies across the Group, to avoid situations where a director’s ability to apply judgement or act in this role is, or has the potential to be, impaired or influenced in some way by a competing interest. During the year a training video on “Directors’ Duties and Corporate Governance” was viewed by all newly appointed legal directors within the Group, as a useful introduction or refresher of the duties of a legal director and best practice.

Stakeholder engagement – Shareholder, employees, customers, suppliers and community and environment

• Shareholders – the Board is committed to openly engaging with its shareholders through regular meetings and calls to discuss strategic matters and objectives so that any feedback, issues or questions can be properly considered.

• Employees – the Group’s employees are fundamental to the commercial success of the business. The Group is committed to operating with the highest ethical standards and strives to be a fair, equitable and inclusive employer through its people practices, including the Group’s approach to recruitment, pay, benefits and career development. As a “Fully Virtual” organisation, our goal is for employees to feel free to work where, when and how they choose (in compliance with regulatory and health & safety requirements) to enable colleagues to balance their personal interests with their work commitments and deliverables, to support a healthier way of life and enhance performance.

  The Group acknowledges that in a Fully Virtual organisation a business needs to work harder to ensure communication, collaboration and connectedness. During 2025 the Group continued to develop and promote openness in communication, multiple forums for engagement with leadership and opportunities to connect with other employees throughout the organisation and Group, and:

  • held regular functional and organisation-wide town halls to promote learning, information-sharing and celebration of successes; and
  • expanded networks and interaction with employees and leaders throughout the organisation to foster greater understanding of the company’s growth strategy, their roles in support of the strategy and to strengthen collaboration among peers and colleagues.
• The Group has a strong in-house Learning & Development programme and this year continued its focus on developing and embedding essential leadership competencies throughout the management community at all levels. This was delivered through the Group’s Management Essentials training, Advanced Management Programme and Authentic Leadership Programme. The Group supported further employee development through access to formal English language training and offering a variety of skills training programmes, including a particular focus on sales enablement. The Group also continued to evolve its Mentoring Programme.

• Customers – the Group aims to provide high quality data and information to its customers and prides itself on developing high quality data products and services using innovation and proven research and development processes. The Group has a dedicated market research function responsible for working with customers to understand their business information needs prior to any new product development and at key points in the development process. This helps to steer the creation of new products and the redevelopment of existing ones.

  The Strategy is explicitly customer-centric, with a focus on delivering trusted, easy to use tools, robust analytics and data driven insights that enable customers to make informed decisions. Initiatives to drive upsell and cross sell, reduce churn, and deepen relationships were evaluated by the Board in light of their potential impact on customer satisfaction, service quality and long-term partnerships. The consolidation of systems and processes throughout the entire organisation and greater integration of data assets are intended to improve consistency, reliability and efficiency for customers and suppliers alike.

• Suppliers – the Group aims to act responsibly and fairly in its engagement with suppliers since these parties are integral to the success of the business. Management monitors the timely payment of supplier invoices on a monthly basis supported by business systems. Our Supplier Code of Conduct provides us with assurance that our suppliers are equally meeting high sustainability requirements; allows us to better assess various risks in our supply chains; and gives us a greater ability to scrutinise the actions being taken by our suppliers to identify and tackle such risks.

• Climate change

  The understanding of climate change and the requirement to take action has become more prominent over recent years which has led to an increase in government initiatives. The 2015 Paris Agreement’s central aim was to pursue efforts to limit the increase of the global temperature rise to 1.5 degrees which has set a new ambition for the world’s response to climate change. The UK Government has targeted to bring all greenhouse gas emissions to net zero by 2050.

  The Group endeavours to reduce its impact on the environment. The goal is to promote sustainability and environmental awareness at all levels by assessing and reducing our carbon footprint; ensuring our staff are aware of the environmental impacts of their work activities and encouraging them through regular awareness and training to minimise those impacts; and working with our suppliers to minimise the environmental impact of products and services we use. The Group is a low energy user, consuming less than 40,000kWh during 2025.

• Community and the environment – The Group has implemented a sustainabiltiy programme, enabling us to embed sustainability within its operations.

  As part of the People & Culture organisation the Sustainability Team along with the Employee Experience team actively promotes and drives sustainability-related initiatives, which include sustainability, social responsibility, employee wellbeing, reporting and governance. During 2025 we continued to implement our Sutainabiltiy Programme and the Group achieved a bronze sustainability rating through EcoVadis, improving its overall score from the prior year, and placing the Group in the top 29% of companies rated by EcoVadis in 2025. This rating is based on assessed criteria in the following four areas: Environment, Labour and Human Rights, Ethics and Sustainable Procurement.

Significant decision after the balance sheet date: response to a cybersecurity incident

After the balance sheet date, one of the Board’s most significant exercises of its section 172 duty concerned the Group’s response to a ransomware incident affecting certain legacy Autovista systems in Europe and Australia. Autovista Information Security identified the incident on 11 April 2026 and immediately activated its incident response protocols, engaging a leading digital forensics and incident response firm and external legal counsel. The directors were kept regularly informed of developments throughout the response. The paragraphs below set out how they had regard to the matters in section 172(1) of the Companies Act 2006 in overseeing it.

• The likely consequences of any decision in the long term

  The directors prioritised a rebuild approach that would strengthen the Group’s security posture over the longer term. Affected environments were rebuilt on hardened infrastructure, subjected to static and dynamic security scanning before being returned to service, and supported by enhanced firewalls, tighter network segmentation and expanded back-up resilience. The directors considered that the Group’s long-term interests were better served by a considered, secure recovery than by a faster but less resilient one.

• The interests of the Group’s employees

  The directors were mindful of the demands the incident placed on the Group’s people. A cross-functional team of approximately 100 employees and external specialists worked around the clock across multiple time zones for three and a half weeks to contain, investigate and remediate the incident, with additional follow-up thereafter. All employees were required to reset their credentials as a protective measure. Employees received regular updates through a special informational hub on the intranet, FAQs, contacts for support and Town Halls. The directors received regular updates on the full response efforts and have since supported continued investment in the tools, protocols and training the team put in place.

• The need to foster the Group’s business relationships with suppliers, customers and others

  The Group engaged specialist third parties, including digital forensics and incident response advisers and external legal counsel, and worked closely with its cyber insurers throughout the response. Special cyber-incident pages were launched on our websites to provide updates and FAQs for customers. The directors placed particular emphasis on maintaining open communication with customers, including through incident summaries, question-and-answer materials and attestation letters describing the containment measures taken, and committed to using regular business reviews to keep customers updated as recovery continued. Where products could not be restored, affected customers were migrated to alternative Autovista solutions.

• The impact of the Group’s operations on the community and the environment

  Although the investigation to date has found no indication that customer personal data was affected, the directors considered it appropriate, out of an abundance of caution, to make precautionary notifications to data protection regulators across the affected European jurisdictions. The directors regarded this as consistent with the Group’s approach to transparency with the wider community of individuals whose data it holds, notwithstanding the absence of a confirmed finding of personal data compromise.

• The desirability of maintaining a reputation for high standards of business conduct

  The Group holds TISAX certification, the information security assessment standard developed for the automotive sector, and this certification was in place and valid at the time of the incident. The directors treated the incident as a further test of, and opportunity to reinforce, the Group’s commitment to high standards of business conduct: engaging independent experts promptly, acting on the additional security recommendations received, and committing to ongoing review of the Group’s security architecture, policies and procedures.

• The need to act fairly as between members of the Company

  The directors considered the financial impact of the incident, including the direct costs of external advisers, and the extent to which these would be offset by the Group’s cybersecurity insurance arrangements. Having regard to the Group’s capitalisation and liquidity position, the directors were satisfied that the Group could absorb the direct costs of the incident without a disproportionate impact on any class of member, and do not currently expect the incident to give rise to material ongoing costs.

As at 1 August 2026, Autovista products and services representing over 99% of the Group’s products and services revenue were fully operational. The directors will continue to monitor the residual impact of the incident, and the effectiveness of the enhanced security measures put in place in response to it, as part of their ongoing oversight of the Group’s affairs.

On behalf of the Board

S Smith
Director

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, forced and compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

We have a zero-tolerance approach to modern slavery and are fully committed to improving our practices to combat slavery, forced and compulsory labour and human trafficking in our corporate activities, and ensuring that high ethical standards are demonstrated and maintained at all times.

This statement sets out the steps we have taken to prevent slavery, forced and compulsory labour and human trafficking from occurring within our organisation and our supply chains.

Our Business

The Autovista Group (the “Group”) is a leading provider of data in the automotive industry, including the provision of pricing insights, along the entire lifecycle of a vehicle across more than 20 countries. Autovista, Autovista24, Eurotax, EV Volumes, Glass’s, Rødboka and Schwacke are our highly-respected, market-leading brands. The Group has more than 720 employees located in the UK, Europe and Australia and operates as a fully flexible business, allowing our employees full flexibility to decide where (within their country of employment) and when they do their work.

On 1 March 2024, the Group was acquired by the J.D. Power group, a global leader in consumer insights, advisory services and data and analytics.

This statement is made on behalf of the UK parent company of the Group, Autovista Bidco Limited, for itself and each of its subsidiaries. The information contained in this statement was obtained from various key stakeholders across the Group including members from the Group’s Leadership, Legal, Risk & Compliance, and People & Performance (HR) teams, and the Group’s Head of ESG.

Our Policies on Slavery and Human Trafficking

The importance of acting with integrity and complying with applicable law, including the UK Modern Slavery Act 2015, is reflected in our Group values (see ‘Our Values’ below). In addition, the Group has various policies in place which are reviewed periodically, to check that they are still current and with a view to increasing their effectiveness, and updated accordingly.

Anti-Slavery and Human Trafficking policy

Our Anti-Slavery and Human Trafficking policy reflects our commitment to acting ethically and with integrity in all our business relationships. It emphasises the Group’s zero-tolerance approach to modern slavery and requires individuals to notify their manager and either their People & Performance (HR) Partner or the General Counsel in the event of any concerns or suspicions concerning modern slavery. These concerns would then be escalated to the Group’s Business Compliance Committee for investigation. The policy also confirms that support and protection will be afforded to those who raise concerns.

Code of Ethics

Our Code of Ethics, which is a policy document applicable to all staff and any other individuals acting on our behalf, underpins our ethical trading position, which is a key strategic focus for the Group. It outlines the Group’s commitment to lawful, ethical, and honest business conduct, emphasising integrity, independence, and fairness, and mandates compliance with applicable laws and regulations, including topics such as anti-slavery and anti-bribery. Breaches of the Code of Ethics may have serious consequences, including dismissal or termination of contractual arrangements.

Recruitment standards

We commit to adhering to the following four UN Global Compact labour principles throughout our operations, and refer to these, and other principles and standards such as the International Labour Organisation’s Fundamental Conventions, in our Code of Ethics:

• Freedom of association and the effective recognition of the right to collective bargaining.
• Elimination of all forms of forced and compulsory labour.
• Effective abolition of child labour.
• Elimination of discrimination in respect of employment and occupation.

We ensure that all staff working for us are engaged in accordance with the law and are paid at least the minimum wage of their country of employment. Employees involved in recruitment have a full understanding that qualifications, skill and experience are the bases for recruitment, placement, training and advancement of staff at all levels. This is supported by the Group’s “Hiring Manager Toolkit” which is accessible to those involved in recruitment. The toolkit provides guidance on fair and consistent recruitment selection processes and a mechanism to support objective evaluations during recruitment. We undertake right to work checks in accordance with local requirements on all employees prior to them commencing their employment and this includes checking, where applicable, that the employee has a valid work visa and is of an appropriate age to work. We also make employment contracts available to all employees stating the terms and conditions of service (including appropriate termination rights), which are in languages easily understood by them.

Whistleblowing policy

All staff who have any concerns that modern slavery, or any other wrongdoing, may be occurring in any part of our organisation or supply chains are encouraged to notify senior management so that the issue can be escalated appropriately and investigated effectively. We have processes and policies in place to protect whistleblowers and their anonymity. The Group also has an anonymous whistleblowing application in operation, which is a simple, secure, anonymous and confidential way in which staff can communicate misconduct (or suspected misconduct), including in relation to modern slavery matters. There are links to the whistleblowing application in various places on the Group’s staff intranet, including the homepage, and in the Group’s Whistleblowing policy itself. In accordance with this policy, staff can also raise concerns with our People and Performance (HR) Team or the General Counsel in confidence to discuss any wrongdoing. No reports were made in 2024. We also periodically host employee forums, which promote transparency and offer employees another route to raise any concerns they may have.

Policy accessibility

All of our policies, including those mentioned above, are available on the Group’s staff intranet.

This ensures that (i) they are readily and easily accessible by all of our employees, and (ii) the prevention of modern slavery from occurring within the Group’s business and its supply chain is embedded as standard practice. All Group employees are required to have a good understanding of the English language, and consequently, all policies, documents and communications are primarily in English, with some also in local languages where necessary. When employees need to be notified about significant changes or updates to the Group’s policies or processes, one of the methods used to alert employees is the Group’s staff intranet.

Our Supply Chains

The Group sources data, including market observations, for its products from a variety of reputable data suppliers, such as vehicle manufacturers, car portals, auction houses and dealers. Our supply chains include suppliers from a number of sectors, particularly the motor industry, IT software and hardware, and professional services. We also occasionally use agencies to supply agency staff.

We seek to ensure that those within our supply chains align with our ethics and values. In some cases (as detailed further below) we review commitments made by our suppliers in their policies and statements. Further, wherever possible, we seek to include appropriate provisions requiring compliance with applicable laws in our supplier contracts, and include specific reference to modern slavery legislation (for example, the UK Modern Slavery Act 2015 or the Australian Modern Slavery Act 2018). The standard provisions were updated in 2024 and stipulate, amongst other things, that (i) suppliers shall take steps to ensure there is no modern slavery or human trafficking in its supply chains or in any part of its business, (2) suppliers must notify the Group as soon as it becomes aware of any actual or suspected slavery or human trafficking in its supply chain, and (iii) the Group can terminate the agreement with the supplier in the event of a breach of these obligations. The terms also include warranties relating to information provided by suppliers in relation to modern slavery matters.

To date, we are not aware of any slavery or human trafficking in our supply chains. If we were to become aware of any such activity in the future, the Group’s Business Compliance Committee would undertake an urgent and thorough investigation and consider the appropriate action which is to be taken, which could include working with the relevant supplier to ensure that effective measures are implemented to address the issue, or terminating our business relationship with that supplier.

As part of the Group’s initiative to identify and mitigate risks and to enable us to (i) get a better understanding of our suppliers, (ii) better assess the level of modern slavery risks in our supply chain, and (iii) scrutinise with greater ability the actions being taken by our suppliers to identify and tackle such risks, an internal guidance document (the “Framework”) includes a section called “Supplier Selection and Purchasing” which incorporates various processes relating to supplier selection and management, amongst other matters.

Supplier Code of Conduct

The Framework includes a requirement that certain suppliers who are engaged by the Group must sign our Supplier Code of Conduct (the “Code”), which sets out the standards the Group expects in relation to various matters, including compliance with anti-slavery legislation, regulations and directives and its reporting obligations in the countries and communities in which the supplier and its supply chain operate. In circumstances where the new supplier fails to sign the Code, they are required to provide various policies and statements to the Group for review by the Group’s Head of ESG, including their modern slavery policy and statement, to ensure that such suppliers have established processes, procedures and protections in place.

The Group’s People & Performance (HR), Legal, and Risk & Compliance teams are primarily responsible for dealing with any risks or concerns raised by the business in relation to modern slavery, which will be escalated to the Business Compliance Committee for investigation and further action, if necessary. These teams are central Group functions, whose leaders form part of the Group’s Executive Management Team and Business Compliance Committee.

Our Values

Trust, Integrity, Innovation, Openness, Respect and Inclusion: these are the values that underpin the culture at Autovista Group. These values are core to all that we do as a business and they set the tone for how we treat each other, our customers, suppliers, stakeholders and third parties. We talk in detail about our values and how they are reflected in practice on our corporate website and we have a page on our Group’s staff intranet dedicated to our values.

Due to the critical importance of our values to the running of our business, we have continued the delivery of our updated management training programme in order to further embed our Group values into the practices and conduct of our managers. This training is mandatory for all people managers across the Group and introduces our leadership competency framework, which specifically references our Anti-Slavery and Human Trafficking policy. This framework is also publicised on the leadership page of the Group’s staff intranet.

Social Audits

In October 2024, EcoVadis, a leader in providing business sustainability ratings, undertook an audit of the Group which included a review of the Group’s management systems relating to Environmental, Labour and Human Rights and specifically in the following areas: employees’ health and safety; working conditions; labour relations; child and forced labour; diversity, discrimination & harassment; and external stakeholder human rights. As a result of the audit, EcoVadis awarded the Group its Bronze Award in recognition of the quality of the Group’s various management systems, which places the Group among the top 24% of businesses assessed by EcoVadis worldwide. In 2024, the Group’s overall score remained the same as in 2023, which reflects the Group’s dedicated approach to maintaining its business sustainability standards.

Awareness

To ensure that our employees across the Group have a base level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, all employees are periodically required to re-read key Group policies, including (amongst others) our AntiSlavery and Human Trafficking policy, our Anti-Bribery & Corruption policy and our Code of Ethics and sign an acknowledgement form that they have read and understood the contents and requirements of the policies. We are able to track and report on which employees have completed this activity using our HR system and, when the process was last undertaken, all employees in the Group (other than longer term absentees) had signed the form.

We also raise awareness of modern slavery and human trafficking through our mandatory annual Governance, Risk and Compliance training, which is reviewed periodically and which includes a module on preventing modern slavery (the “GRC Training”). In 2024, all employees were required to complete the GRC Training within a specified time period. All new starters are also required to complete this training when they join the Group as part of the employee induction process. After finishing the training, employees are required to demonstrate their understanding by completing a questionnaire, which is updated annually, and this is tracked through our HR system.In addition, our Executive Management team attended training led by external legal counsel in November 2024 covering, amongst other things, ethical business practices.

Employees are notified once the Group’s annual modern slavery statement has been published on the Group’s website and they are encouraged to read it.

We also included details of how we increased awareness of modern slavery with our employees, and referred to our last modern slavery statement, in our UK group consolidated annual financial statements for the year ended 31 December 2024, and continue to register our modern slavery statements with the UK Government’s modern slavery statement registry to enhance the transparency and accessibility of our commitments in relation to anti-slavery.

Our registration in 2024 for the period 1 January 2023 to 31 December 2023 can be found on the UK Government’s website.

Further Steps

We will continue to provide our employees with the necessary training and resources to ensure a commitment to the highest standards of ethical behaviour, and employees will be required to recomplete the GRC Training again in 2025, with a refreshed set of questions to check their understanding.

In 2025, we intend to increase oversight of our supply chain by consolidating the information we hold on our suppliers, including acceptance of the Code by suppliers, in order to improve our tracking and reporting abilities, and awareness of any modern slavery risks in our supply chain .

The Group will continue to raise awareness of the prevention of modern slavery among its employees by including a special agenda item on preventing modern slavery in the employee forum meeting which is scheduled for May 2025.The Group’s Legal team is committed to ensuring that the Group is aware of any developments in the prevention of modern slavery and will continue to attend relevant training courses and disseminate useful information and guidance.

Our commitment to a sustainable business will be independently verified in 2025 through our reassessment by EcoVadis. Through this reassessment, the Group is able to validate its commitment to ethical practices, and we are striving to match or improve our EcoVadis rating each year.

Section 54(1)

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2024. This statement has been authorised and approved by the board of directors of Autovista Bidco Limited.s our slavery and human trafficking statement for the financial year ending 31 December 2023. This statement has been authorised and approved by the board of directors of Autovista Bidco Limited.

Signed:

Tom Ovenden – Signature

Authorised signatory, for and on behalf of Autovista Bidco Limited

Date: 26 June 2025

This tax strategy is published by Autovista Bidco Limited (“Bidco”) in accordance with the requirements of paragraph 19(2) of Schedule 19 of the UK Finance Act 2016. It applies to Autovista Bidco Limited and all of its subsidiaries (the “Group”). It is effective for the financial year ending 31 December 2025 and will be reviewed annually and updated as necessary.

All references to tax legislation and tax authorities are to UK tax legislation and HM Revenue & Customs but equally apply to legislation and authorities in all other territories in which the Group operates.

Governance, risk management and compliance

The Group is committed to acting with integrity, including high standards of corporate governance, and transparency on tax matters both within the letter and spirit of relevant tax law and international standards.

Our tax strategy is approved by the Bidco Board, with the Chief Financial Officer having oversight responsibility on behalf of the Bidco Board. The tax team are responsible for the implementation of the tax strategy with assistance from the finance team.

The Group has tax compliance processes in place to ensure the integrity of its tax filings and timely and accurate tax payments in all countries in which it operates. This includes utilising third-party service providers whose performance is actively monitored. Tax related approvals are documented in the group’s authority framework.

Tax planning

We do not engage in transactions without commercial substance or with the sole purpose of achieving a contrived tax result. The Group considers the tax consequences of transactions as part of its planning processes, applying the legislative framework of the territories in which we operate. All planning decisions consider reputational, commercial, and regulatory implications.

Approach to tax risk

The tax team’s aim via appropriate processes, policies and governance framework is to support the business to ensure tax risks are appropriately identified, assessed and managed. For example, the Business Compliance Committee meet at least on a quarterly basis, with Anti-Facilitation of Tax Evasion as a standing agenda item.

The international tax environment is complicated with local tax laws often complex and subject to change and interpretation. Our processes, policies and governance framework are in place to minimise risks that arise from operating internationally.

We have a low tolerance towards tax risk and seek advice from external tax advisers where appropriate, for example where there is uncertainty or complexity, to minimise such risks arising and manage potential risks.

Approach towards relationship with Tax Authorities

We seek to develop and maintain an open and collaborative working relationship with tax authorities. We are committed to responding to information requests proactively, transparently and promptly, assisted by external tax advisers where appropriate.

Where the application of tax law is unclear, we obtain professional advice and where local legislation permits, we may seek confirmation of our position from the relevant tax authorities.

Approved by the Board: 24 November 2025

This tax strategy is available on the Autovista Group website and will be reviewed annually in line with legislative requirements.

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Thorsten Barg
Dr. Christof Engelskirchen

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