Modern slavery &
human trafficking

Rainly Ltd is committed to preventing modern slavery and human trafficking in its business and supply chains. This statement describes the steps taken by Rainly Ltd during the financial year from 1 January 2026 to 31 December 2026 to identify, prevent, mitigate and respond to modern slavery risks.

This statement has been prepared with regard to section 54 of the Modern Slavery Act 2015, the Home Office statutory guidance on transparency in supply chains and the principles of Procurement Policy Note 009: Tackling Modern Slavery in Government Supply Chains. It applies to Rainly Ltd’s directors, employees, contractors, suppliers and business partners involved in delivering its services.

Rainly Ltd is a private limited company registered in England and Wales under company number 14525292. Its registered office is 320 Firecrest Court, Centre Park, Warrington, England, WA1 1RG. Housing Perks is a trading style and registered trademark of Rainly Ltd. References to “Rainly”, “the Company”, “we”, “us” and “our” in this statement include the Housing Perks business.

Rainly develops and operates digital products that help social-housing residents access discounts, cashback, vouchers and other financial benefits. Housing Perks works with social landlords and commercial partners to provide the service.

Our supply chain consists principally of technology and cloud-service providers; software and information-security suppliers; payment, voucher and related service providers; participating retailers and offer partners; marketing and customer-support services; and legal, financial, compliance and other professional advisers. Most direct suppliers are based in the United Kingdom or European Union, although some suppliers may themselves rely on international or extended supply chains.

We do not tolerate slavery, servitude, forced or compulsory labour, human trafficking, debt bondage, deceptive recruitment, the withholding of identity documents or any other form of severe labour exploitation in our operations or supply chains.

Everyone working for or on behalf of Rainly is expected to act ethically, comply with applicable labour and human-rights laws and report concerns promptly. This commitment is supported by our Code of Conduct, Anti-Bribery and Corruption Policy and Whistleblowing Procedure.

During the financial year ended 31 December 2026, Rainly applied its supplier onboarding and due-diligence process to new suppliers and contractors. The process considered ethical practices, employment standards and compliance with applicable modern-slavery, labour and human-rights laws.

The Company requested relevant supplier assurances, included labour and anti-slavery obligations in contracts with key suppliers, and retained procurement and due-diligence records for review. Higher-value supplier appointments were subject to the Company’s formal procurement procedure, including checks proportionate to the nature of the service and the identified risk.

Rainly also maintained confidential internal reporting routes, incorporated modern-slavery awareness within its compliance training, and provided more focused guidance to managers and colleagues involved in procurement or supplier management. Supplier compliance, concerns and grievances were monitored through the Company’s existing compliance and oversight processes.

Rainly recognises that no sector or country is entirely free from modern-slavery risk. Our assessment considers the six risk characteristics used in PPN 009: industry type; the nature of the workforce; supplier location; the context in which the supplier operates; the type of commodity or service; and the relevant business and supply-chain model.

Our directly controlled operations are assessed as presenting a lower inherent risk because Rainly is a UK-based technology business with a small, directly engaged workforce and no labour-intensive manufacturing operation. This is not treated as an absence of risk.

Potential exposure is more likely to arise through third-party and extended supply chains, particularly where services depend on outsourced, temporary, migrant or lower-paid labour; recruitment intermediaries; operations in jurisdictions with weaker labour protections; complex subcontracting; or the manufacture and distribution of electronic equipment and other goods. Payment, voucher, retailer, cloud and technology relationships may also connect Rainly to supply chains beyond its immediate contractual counterparty.

Risk findings determine the level of due diligence applied. Where higher-risk characteristics are identified, the Company may request further supply-chain information, policies and evidence; assess recruitment and workforce practices; require contractual controls and a time-bound improvement plan; monitor delivery more closely; or commission further review. The risk assessment is reconsidered when onboarding or renewing a supplier and when material changes, concerns or adverse information arise.

New suppliers and contractors are expected to confirm compliance with applicable labour, human-rights and anti-slavery laws. Due diligence is proportionate to the supplier’s location, workforce, service, supply-chain complexity, contract value and influence on delivery of the Housing Perks service.

Contracts with key suppliers include obligations to comply with applicable laws and ethical standards. Rainly may seek information about subcontractors and extended supply chains where this is relevant and proportionate, particularly for public-sector contracts or where a procurement is assessed as presenting increased modern-slavery risk.

Employees are required to complete compliance training covering ethical conduct, modern slavery and whistleblowing. Managers and colleagues involved in procurement or supplier management receive additional guidance on identifying warning signs, escalating concerns and applying proportionate due diligence. Training content is reviewed to reflect legal developments, public-sector procurement guidance and emerging risks.

Employees, contractors, suppliers and other business partners are encouraged to report suspected modern slavery to the Compliance Officer or through Rainly’s confidential whistleblowing arrangements. Reports are handled sensitively, investigated promptly and protected from retaliation when raised in good faith.

Our response is victim-centred. Where a concern is substantiated or reasonably suspected, Rainly will first consider the immediate safety, rights and welfare of affected workers; preserve confidentiality where possible; and obtain appropriate specialist or legal advice. The Company will cooperate with law-enforcement, safeguarding bodies or other competent authorities where appropriate and will contact the emergency services if anyone is in immediate danger.

Rainly will assess each case individually and seek to avoid action that could unintentionally worsen a worker’s situation. Depending on the severity and circumstances, we may require the supplier to implement a time-bound remedial action plan, protect affected workers, correct recruitment or employment practices, repay improper fees or withheld sums, improve grievance routes and provide evidence of completion. Suspension or termination may be used where necessary, particularly if a supplier refuses to cooperate, fails to remedy the issue or the risk cannot be managed safely. Decisions will take account of potential consequences for affected workers.

Rainly monitors the effectiveness of its approach through supplier due-diligence records, internal compliance reviews and the monitoring of whistleblowing reports and grievances. Findings are used to update risk assessments, contract controls, guidance and training. The Company will continue to strengthen its supplier mapping and the evidence retained to demonstrate actions taken each year.

The Board of Rainly Ltd is responsible for this statement. Senior management, supported by the Compliance Officer, oversees implementation, monitoring and annual review. The statement will be reviewed at least once a year and updated sooner where there is a material change in the Company’s structure, activities, supply chain, risk profile or applicable requirements.

Following approval and sign-off, this statement will be published on the Housing Perks website. Rainly intends to retain previous annual statements online so that stakeholders can assess progress over time.

Board approval date: 2nd January 2026

Signed for and on behalf of Rainly Ltd by: A. Clegg

Position: Director

Date signed: 2nd January 2026