Compliance

Modern Slavery Statement

This statement is made pursuant to section 54 of the United Kingdom's Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement of the Fontana group for the current financial year. It is published voluntarily; the group's UK turnover for the current period does not yet trigger the mandatory £36m threshold, but Fontana adopts the section 54 framework as a matter of good governance and to give buyers, banks and counterparties visibility on our supply-chain due diligence.

1. Our structure and business

Fontana Trading Europe, Sociedade Unipessoal Lda. (NIPC 519 541 227) is the parent company of the Fontana group, headquartered in Lisbon, Portugal. The group holds two wholly-owned subsidiaries:

• Fontana Agronegócios Ltda. (Brazil, CNPJ 54.793.783/0001-37) — origination of soybean and corn in the Cerrado biome of western Bahia and adjacent MATOPIBA states (Maranhão, Tocantins, Piauí).
• Fontana Trading UK Ltd. (United Kingdom) — international trading, with responsibility for GBP and USD contracts under English law and for China, Africa and global commodity desk relationships.

The group buys grain from Brazilian farms and cooperatives, contracts logistics through Brazilian ports (Santos, Paranaguá, Itaqui, Barcarena), and sells to importers, crushers, biofuel producers and feed manufacturers across the European Union, the United Kingdom, China, North Africa and other destinations.

2. Our supply chain

The parts of our supply chain most relevant to modern slavery risk are:

• Rural labour in Brazilian agriculture — soy and corn cultivation in the Cerrado is mechanised at scale, which limits but does not eliminate the risk of degrading working conditions or debt-bondage recruitment, particularly at harvest peaks and in adjacent labour-intensive activities.
• Inland transport — trucking from farm gate to port terminal involves independent operators and driver cooperatives where working-hour and rest-period standards vary.
• Port operations and stevedoring — governed by Brazilian labour law and port-authority collective agreements, generally lower risk but monitored.
• International shipping crews — deep-sea bulk carriers use crews of varying nationality; conditions are governed by the Maritime Labour Convention 2006 (MLC), but flag-of-convenience vessels can present elevated risk.
• Corporate services — cleaning, catering, security and IT services procured for the Lisbon and London offices, sourced from vetted local suppliers.

3. Policies

Our commitment to preventing modern slavery is expressed through the following policies:

• This Modern Slavery Statement.
• KYC & Counterparty Policy — every supplying farm and every commercial partner is onboarded through documented due diligence.
• Anti-Bribery & Corruption Policy — the same reporting channel receives modern slavery concerns.
• Sanctions Policy — including screening against lists that overlap with human trafficking sanctions programmes.
• Group Code of Conduct — signed by every employee on joining.
• Whistleblowing procedure — anonymous reporting channel, protection against retaliation.

4. Due diligence in Brazilian origination

Every farm from which the group originates grain is checked against the following public and private data sources at onboarding and at least annually thereafter:

• "Lista Suja" do Trabalho Escravo — the Brazilian Ministry of Labour's public register of employers found by the labour inspectorate to have used labour analogous to slavery. Any match results in immediate suspension of the origination relationship and formal review.
• Cadastro Ambiental Rural (CAR) — the environmental register that links a property polygon to its owners. Used to establish farm identity and locate operations for satellite monitoring.
• IBAMA and ICMBio embargo lists — environmental infractions that often correlate with labour risks.
• Soy Moratorium and Cerrado Working Group commitments — signatories monitored against deforestation, a proxy for weak governance.
• PRODES and DETER satellite deforestation data — polygon-level checks per farm plot.
• ONG, media and NGO adverse-media search — quarterly.

A positive finding on any of the above triggers a hold on future origination from the farm, an in-person or remote follow-up with the counterparty, and formal review by the Head of Compliance. Reinstatement requires evidence of remediation and, where the "Lista Suja" is involved, removal from the list.

5. Due diligence in logistics and shipping

Trucking contractors and driver cooperatives providing farm-to-port road transport are required, through terms in the freight contract, to comply with Brazilian driver-hours legislation (Lei nº 13.103/2015). Terminal operators are contracted through group agreements with the major Brazilian ports and are subject to Brazilian labour law and port-authority collective agreements.

For international shipping, Fontana's charter-party clauses require the vessel and its operator to be Maritime Labour Convention 2006 compliant, to hold a valid Maritime Labour Certificate, and to maintain a P&I club entry. Vessels flagged in jurisdictions associated with elevated labour risk are declined or subject to additional documentary checks before fixture, consistent with the vessel due diligence described in the Sanctions Policy.

6. Training

All group employees complete modern-slavery awareness training as part of onboarding and every 24 months thereafter. Staff with direct origination or commercial responsibilities receive extended training covering identification of red flags in the Brazilian rural context (payment of workers, housing conditions, freedom of movement, document retention, recruitment fees).

7. Reporting

Anyone with information about actual or suspected modern slavery within Fontana's operations or supply chain is asked to report through:

• Email to compliance@fontana.trade.
• Post to the Head of Compliance, Fontana Trading Europe, Sociedade Unipessoal Lda., Rua Filipe Folque 2, 2º, 1050-113 Lisboa, marked Private and Confidential.
• Anonymously.

Reports are received by the Head of Compliance. Retaliation against any person making a good-faith report is a dismissible offence. Where a report indicates a criminal offence, the group cooperates with the competent authority in the relevant jurisdiction.

8. Measuring effectiveness

The group tracks the following indicators annually and reviews them at CEO level:

• Percentage of supplying farms screened against the Lista Suja and CAR at onboarding: target 100%.
• Percentage of supplying farms re-screened annually: target 100%.
• Number of modern-slavery concerns raised, investigated and closed.
• Percentage of directly employed staff completing training within due date.
• Number of vessels declined at fixture on labour or MLC grounds.

9. Approval

This draft statement will be formally approved by the board of Fontana Trading Europe, Sociedade Unipessoal Lda. and signed by a director before publication as the group's finalised section 54 statement. It will thereafter be reviewed and republished annually. The signed and dated version will replace this draft at the same URL.