Modern Slavery and Human Trafficking Statement

1
Statement and Commitment

This statement sets out the approach taken by AORO ENERGY LTD,
trading as AORO Solar UK, to identify, prevent and address modern
slavery, forced labour and human trafficking risks within its
business operations and supply chain.

It covers the financial year from 1 June 2025 to 31 May 2026
and has been prepared with regard to section 54 of the Modern
Slavery Act 2015 and the accompanying Home Office guidance on
transparency in supply chains.

Modern slavery represents a serious violation of fundamental human
rights and may take several forms, including slavery, servitude,
forced or compulsory labour and human trafficking.

These risks can be particularly relevant within sectors involving
construction, infrastructure delivery, logistics, subcontracted
labour, raw-material extraction and international manufacturing
supply chains.

Our approach is intended to develop in proportion to the scale,
complexity and risk profile of our operations. We recognise that
responsible business conduct requires continuing review, improved
visibility and constructive engagement with suppliers, contractors
and business partners.

2
Organisational Structure, Business Model and Operations

AORO ENERGY LTD is a company incorporated in England and Wales
under company number 15308155 and operates under the AORO Solar UK
brand within the United Kingdom renewable energy sector. The
Company was known as NIMBUS NINE LTD during the reporting period
and changed its legal name to AORO ENERGY LTD on 20 June 2026.

The Company specialises in the design, supply, installation,
commissioning, monitoring and long-term support of solar
photovoltaic systems, battery storage technologies, electric
vehicle charging infrastructure and integrated energy solutions.

Our activities may serve residential customers, commercial
organisations, property developers, agricultural businesses and
other infrastructure-related clients across the United Kingdom.

The Company’s delivery model may involve a combination of direct
project execution, employees, specialist contractors, installation
partners, logistics providers, professional advisers and domestic
and international equipment suppliers.

This operating model requires a structured and proportionate
approach to governance, labour standards, responsible procurement,
supplier management and supply-chain oversight.

3
Supply Chain Structure and Exposure

The Company’s supply chain may extend across several jurisdictions
and may include organisations involved in the manufacture,
distribution, transportation, installation and support of renewable
energy equipment.

Relevant categories of suppliers and business partners may include:

• manufacturers of photovoltaic modules, mounting equipment and
  associated components;
• manufacturers of battery storage systems, inverters and energy
  management equipment;
• distributors and wholesalers of electrical and renewable energy
  products;
• logistics, freight, warehousing and delivery providers;
• specialist contractors, installation partners and technical
  service providers;
• software, monitoring, communications and infrastructure
  providers;
• professional, advisory, financial and administrative service
  providers.

AORO ENERGY LTD recognises that modern slavery risks may arise at
different levels of a supply chain, particularly within upstream
manufacturing, raw-material sourcing, logistics and
labour-intensive contracting activities.

We also recognise that visibility may reduce at deeper tiers of a
supply chain, increasing the difficulty of identifying and
addressing unethical labour practices.

The Company therefore seeks to apply a structured and proportionate
approach to supply-chain risk management, taking account of
geographic, sectoral, commercial and operational factors.

4
Risk Assessment and Risk Management Approach

AORO ENERGY LTD applies and continues to develop a proportionate,
risk-based approach to identifying, assessing and prioritising
potential exposure to modern slavery.

Indicators considered as part of this approach may include:

• the geographic location of suppliers, production facilities and
  manufacturing activity;
• known industry-specific labour and human-rights risks;
• the use of temporary, migrant, agency or subcontracted labour;
• the transparency, traceability and ownership of supplier
  operations;
• unusually low pricing or unexplained commercial anomalies;
• the complexity and depth of the relevant supply chain;
• the availability and reliability of supplier information;
• adverse reports, regulatory concerns or credible allegations
  relating to a supplier or jurisdiction.

Particular attention may be given to overseas manufacturing
environments, labour-intensive activities and supplier
relationships where operational visibility is limited.

The Company intends to review and refine its risk-assessment
methodology as its operations, procurement activity and supplier
network develop.

5
Due Diligence Processes and Supplier Management

AORO ENERGY LTD seeks to apply appropriate due diligence when
selecting, onboarding and managing suppliers, contractors and
business partners.

The nature and depth of the review may vary according to the value,
strategic importance, location, sector and risk profile of the
proposed relationship.

Depending on the circumstances, due diligence may include:

• verification of supplier identity and legal status;
• assessment of operational and commercial credibility;
• review of available compliance, ethical and reputational
  information;
• requests for assurances concerning labour standards and
  responsible employment practices;
• consideration of the supplier’s own supply-chain controls;
• review of relevant policies, statements or certifications where
  appropriate;
• escalation of material concerns for further assessment.

Supplier Due Diligence Lifecycle

Suppliers, contractors and partners are expected to comply with
applicable labour laws and to support principles consistent with
the prevention of slavery, servitude, forced labour and human
trafficking.

Where material concerns are identified, the Company may request
further information, require corrective action, increase
monitoring, suspend engagement or terminate the relationship,
depending on the nature and seriousness of the concern.

6
Procurement Controls and Contractual Safeguards

Ethical considerations form part of the Company’s procurement and
supplier-management approach.

Supplier selection may take account of commercial, operational,
technical and ethical considerations, including potential exposure
to modern slavery and wider human-rights risks.

Where appropriate and proportionate, supplier contracts, purchase
terms or related documentation may include:

• obligations to comply with applicable laws and labour standards;
• representations relating to forced labour, human trafficking and
  employment practices;
• requirements to notify the Company of relevant concerns or
  investigations;
• rights to request supporting information or evidence;
• requirements to implement appropriate corrective or remedial
  measures;
• suspension or termination rights in the event of a material
  breach.

The Company seeks to balance commercial efficiency, continuity of
supply and project delivery with responsible procurement and
ethical business practice.

7
Governance and Internal Controls

Ultimate oversight of the Company’s approach to modern slavery
rests with the Board of Directors of AORO ENERGY LTD.

Senior management is responsible for supporting the implementation
and continuing development of appropriate controls within
procurement, operations, project delivery and supplier management.

Relevant operational functions are expected to:

• identify potential modern slavery and labour-related concerns;
• escalate material risks through appropriate management channels;
• maintain proportionate supplier and decision records;
• support supplier assessment and periodic review;
• contribute to corrective and remedial action where required.

Governance Structure

The Company intends to strengthen the allocation of responsibilities,
reporting arrangements and management information as its governance
framework develops.

8
Reporting, Whistleblowing and Incident Management

AORO ENERGY LTD encourages employees, contractors, suppliers,
customers and other stakeholders to report concerns relating to
modern slavery, forced labour, human trafficking or unethical
labour practices.

Concerns may be raised confidentially and should be handled without
retaliation against individuals who report a concern honestly and
in good faith.

Credible reports will be assessed and, where appropriate,
investigated. Potential responses may include:

• engagement with the relevant supplier or contractor;
• requests for additional information or supporting evidence;
• corrective or remedial action plans;
• increased monitoring or further due diligence;
• suspension of procurement or project activity;
• termination of the relevant business relationship;
• referral to law-enforcement, regulatory or specialist authorities
  where appropriate or legally required.

Incident Management Process

The Company recognises that remediation should take account of the
rights, interests and safety of potentially affected individuals.
Ending a commercial relationship may not always represent the most
responsible immediate response where it could increase harm to
vulnerable workers.

9
Training and Awareness

AORO ENERGY LTD recognises that awareness is an important component
of preventing and identifying modern slavery.

The Company seeks to ensure that personnel with responsibilities in
procurement, operations, supplier management and project delivery
understand:

• the principal indicators of modern slavery and exploitation;
• how concerns should be identified, recorded and escalated;
• the importance of responsible and transparent procurement;
• the Company’s expectations of suppliers, contractors and
  commercial partners;
• the need to consider affected individuals when deciding on
  remediation.

As the Company develops, it intends to introduce more structured
training and awareness measures proportionate to the nature of its
activities and identified risks.

Training priorities may include personnel with direct responsibility
for purchasing, supplier onboarding, contract management, operations
and project delivery.

10
Monitoring, Review and Continuous Improvement

AORO ENERGY LTD is committed to the continuing development of its
systems, governance and controls relating to modern slavery and
responsible procurement.

Monitoring and improvement activities may include:

• periodic review of relevant supplier relationships;
• refinement of supplier screening and due-diligence processes;
• improvement of contractual protections and supplier terms;
• enhancement of internal escalation and reporting arrangements;
• review of identified concerns, incidents and remedial actions;
• assessment of the practical effectiveness of relevant controls;
• consideration of changes in legislation, regulation and industry
  good practice.

The Company recognises that modern slavery risks evolve over time
and that its approach must remain responsive to changes in its
operations, markets, technologies and supplier network.

11
Future Development and Strategic Direction

As part of its growth strategy, AORO ENERGY LTD intends to continue
developing its compliance, ethical sourcing and
responsible-procurement framework.

Future measures may include:

• enhanced monitoring of strategically important suppliers;
• more detailed supplier risk classification;
• structured supplier questionnaires and declarations;
• targeted third-party assurance or audit activity where
  proportionate;
• improved internal management information and reporting;
• integration of wider environmental, social and governance
  considerations into procurement decisions;
• development of appropriate performance indicators for relevant
  compliance activities;
• periodic review of supplier standards, contract wording and
  escalation procedures.

These measures will be introduced progressively and in a manner
proportionate to the scale, complexity and risk profile of the
Company’s operations.

12
Approval, Review and Contact

This statement describes the approach of AORO ENERGY LTD for the
financial year ended 31 May 2026 and will be reviewed annually to
ensure that it remains relevant and proportionate to the Company’s
operations and supply chain.

Reporting a Concern

Concerns relating to modern slavery, human trafficking, forced
labour or unethical labour practices may be reported to the Company
using the contact details below.

This statement was approved by the Board of Directors of
AORO ENERGY LTD on 25 July 2026 and is signed on behalf of the
Company.