MERLIN

ENTERTAINMENTS
MODERN SLAVERY STATEMENT
FOR 2023
FOREWORD
At Merlin Entertainments we have a zero-tolerance approach to modern slavery of any kind within our
operations and supply chain. As such we are committed to conducting business responsibly and will always
endeavour to ensure that no modern slavery or human trafficking occurs in the operation of our business.

We expect all areas of our business, and all suppliers and contractors, to comply with internationally recognised
codes of practice on human rights, employment practices and working conditions.

For certain procurement categories, we undertake further reviews to assess suppliers against requirements as set
out in international standards such as SA8000 or similar.

Part of our core values as a company is based on the respect and care of human rights and we will always take
decisive action to do the right thing. As a business we believe that everyone matters and have always strived to
create environments where our offices, attractions and resorts are safe, inclusive and diverse, and where everyone
has the same opportunities and respect.

Merlin will always seek to do the right thing by its employees and its communities and operates within a framework
of continuous self-assessment and improvement. Scott O’Neil
Chief Executive Officer
June 2024

MERLIN ENTERTAINMENTS | MODERN SLAVERY STATEMENT 2023

 Merlin is a global leader in branded entertainment destinations.
As Europe's Number 1 and the world's second-largest visitor attraction operator, Merlin now
operates over 140 attractions, 24 hotels and six holiday villages in 23 countries and across
four continents. The company aims to deliver memorable, immersive brand experiences to

BUSINESS millions of visitors worldwide, through global and local brands, and has circa 30,000 employees
during peak season.
STRUCTURE The business is split into three main operating groups: Gateway Attractions, LEGOLAND
Parks and Resort Theme Parks. The three operating groups are supported by a central
corporate team and Merlin Magic Making (“MMM”), our unique internal creative and
production resource. Procurement policies and strategy are centrally led and locally
implemented, with commitments to suppliers made by each attraction and operating under the
MERLIN ENTERTAINMENTS | MODERN SLAVERY STATEMENT 2023 2
delegated authority principle.
 POLICIES
We are committed to identifying and addressing modern slavery and human trafficking risks in our business and our
supply chains.

As an organisation operating in multiple jurisdictions, we will always comply with local laws and regulations, however where these
fall short of our own global standards and policies, we will always aim to go above and beyond local legislation to maintain a high
common ethical standard.

Our Human Rights & Modern Slavery Policy (updated in 2022) reflects our commitment to acting ethically and with integrity
in our business activities and relationships. We strive to prevent exploitation and discrimination, to value diversity and inclusion
throughout our business, and to provide a safe, secure and healthy environment within which to work.

As part of our ‘Everyone Matters at Merlin’ strategy, we are committed to leading positive change to increase diversity and
inclusion within our workforce and better reflect the diversity of our millions of guests. In 2022 and 2023, much of our focus in
this area has been on driving internal change through increasing the diversity of our employee population and continuing to foster a
culture of inclusion for all. Alongside this we have, and will continue to, increase externally-facing activity and introduce more ways
of showcasing our culture of inclusion and belonging.

MERLIN ENTERTAINMENTS | MODERN SLAVERY STATEMENT 2023 3

 POLICIES

Whistleblowing Policy (updated in 2024) Employee Code of Conduct

The Company encourages all employees to report any concerns The Code of Conduct makes clear to employees
relating to the direct activities, or supply chains of the the actions and behaviour expected of them at all
times when representing the Company. The
Company. The policy is designed to make it easy for employees Company strives to maintain the highest standards
to make disclosures without fear of retaliation, through use of of employee conduct and ethical behaviour in all its
an independent externally hosted Whistleblowing Hotline. operations and the Code of Conduct makes clear
that breach of any policy will not be tolerated.
This service is available to all employees, temporary workers and
agency staff in all languages, regardless of where they are in the All employees are required to formally
world. This service is also available to external consultants and acknowledge that they have read, understood and
will adhere to the content of the Code of
contractors employed to work on behalf of Merlin. Conduct. Their declaration also serves as formal
acknowledgement of all Company policies referred
to within the Code (including policies that have
relevance to modern slavery). Through the Code
of Conduct employees are made fully aware that
breach of any policy, or failure to raise concerns,
may lead to disciplinary action and ultimately lead
to dismissal.
MERLIN ENTERTAINMENTS | MODERN SLAVERY STATEMENT 2023 4
 POLICIES

Equal Opportunities Policy Recruitment Policy and Code of

Practice
Available to all UK employees and extended to other regions
based upon local laws. It states all employees should be treated These global policies uphold the Equal
with dignity, respect and consideration at work and does not Opportunities and Human Rights policies
discriminate against them because of sex, age, gender through ensuring that all candidates are treated
reassignment, marital or civil partner status, sexual orientation, with dignity and respect, and that all
disability, race, colour, nationality, religion or belief, ethnic or applications are handled equally.
national origin, maternity or pregnancy.

The Company aims to treat all employees, former employees,

clients, suppliers and other members of the public with whom
the Company comes into contact, with dignity and respect.

MERLIN ENTERTAINMENTS | MODERN SLAVERY STATEMENT 2023 5

 POLICIES

Protection of Children and Young Workers Anti-Bribery and Fraud Policy

This global policy states our commitment to protecting children The Company has zero tolerance towards fraud or
and younger workers under the age of 18. It clearly states the bribery. Facilitation payments by anyone
Company does not tolerate unfair treatment of children or representing Merlin are prohibited anywhere in the
young workers in the workplace and that maximum working world. This policy extends to anyone acting on
hours, working conditions and fair treatment be adhered to at all behalf of the Company as well as to suppliers,
times. consultants and contractors. Such third parties are
required to agree compliance with Merlin's Ethical
Risk assessments are carried out before employing young Dealing Principles (updated in 2023), or equivalent
workers, and the Company takes all measures to ensure that (which include a contractual requirement to comply
child welfare takes priority over business concerns. with applicable anti-bribery legislation).

The application of the policy is underpinned by an

employee training regime that provides a record of
responses to a series of questions to demonstrate
that a user has understood the policy and its
application.
MERLIN ENTERTAINMENTS | MODERN SLAVERY STATEMENT 2023 6
 POLICIES

Retail Merchandise
Contract Code
Policy and ofProfile
Risk Conduct
These documents specifically require suppliers to achieve and
maintain standards in relation to the following:
TheThe
CodeContract Policyand
of Conduct (also updated
Global in 2023) sets out the process for placing contracts on behalf of Merlin from start to
Sourcing
finish and
Principles appliesthe
establish globally to all for
standards employees who place contracts within their role. The Policy requires employees to utilise
commercial
Merlin’s standard contract templates
retail suppliers working for Merlin. where possible.
o prevention of child labour;
WeOur templates
expect require
suppliers suppliers
to comply withtointernationally
adhere to Merlin’s Ethical Dealing Principles
o prevention of forcedwhich are relevant to eliminating the risk
labour;
of modern
recognised slavery
codes and contractually
of practice on Humanrequire
Rights, suppliers to confirm compliance with the Modern Slavery Act 2015. In
addition, Merlin’s
employment Risk
practices andProfile on conditions.
working Supply Contracts identifies o prevention of slave and
the most important trafficked
contract riskslabour;
for our business and sets
out our risk profile on each risk in accordance with a Red-Amber-Green traffic light system.
o ensuring safety;
o health
The Risk Profile also applies globally to all employees placing and on
contracts hygiene;
behalf of Merlin. The risk of unethical conduct
features as an important risk and our preferred or ‘green’orisk profile requires suppliers to
associations, discrimination andcomply with Merlin’s Ethical
coercion;
Dealing Principles.
o working hours and wages; and protection of the environment

MERLIN ENTERTAINMENTS | MODERN SLAVERY STATEMENT 2023 7

 POLICIES

Contract Policy and Risk Profile

The Contract Policy (also updated in 2023) sets out the process for placing contracts on behalf of Merlin from start to
finish and applies globally to all employees who place contracts within their role. The Policy requires employees to utilise
Merlin’s standard contract templates where possible.

Our templates require suppliers to adhere to Merlin’s Ethical Dealing Principles which are relevant to eliminating the risk
of modern slavery and contractually require suppliers to confirm compliance with the Modern Slavery Act 2015. In
addition, Merlin’s Risk Profile on Supply Contracts (updated in 2023) identifies the most important contract risks for our
business and sets out our risk profile on each risk in accordance with a Red-Amber-Green traffic light system.

The Risk Profile also applies globally to all employees placing contracts on behalf of Merlin. The risk of unethical conduct
features as an important risk and our preferred or ‘green’ risk profile requires suppliers to comply with Merlin’s Ethical
Dealing Principles.

MERLIN ENTERTAINMENTS | MODERN SLAVERY STATEMENT 2023 8

 SUPPLY CHAIN

As our supply chain is global in nature, we regularly work with local and national, as well as international, business
partners. The Company will not knowingly do business with any parties who do not comply with applicable laws and
regulations, including local, environmental and employment laws.

Unless a higher or equivalent standard is applied, suppliers are required to agree, as a condition of doing business with Merlin, that
Merlin’s Ethical Dealing Principles will apply. Any requests for amendment must be escalated to senior management in accordance
with Merlin’s Risk Profile. Our Ethical Dealing Principles require suppliers to be compliant with international conventions in relation
to forced labour; freedom of association; right to organise and collective bargaining; equal remuneration; abolition of forced labour;
discrimination; minimum age and child labour; the European Convention on Human Rights and European Money Laundering
Convention. They also require suppliers to be compliant with applicable legislation in relation to bribery and modern slavery.

Suppliers providing certain construction related goods and/or services to Merlin Magic Making are required to participate in a due
diligence and tender process and, if successful, agree Merlin’s standard framework agreement or other appropriate template before
they are admitted to our Preferred Suppliers List. As above, they will be required to agree Merlin’s Ethical Dealing Principles.

In 2022, we engaged a third party provider to conduct certain due diligence on all Tier 1 suppliers (ie. those over £500,000 in value).
Suppliers are assessed against six key risk areas: finance, cyber, sanctions, geopolitical, operations and ESG. In keeping with one of
our aims for 2023, we expanded that due diligence to apply to all Tier 2 suppliers (those over £250,000 in value) as well.

MERLIN ENTERTAINMENTS | MODERN SLAVERY STATEMENT 2023 9

 SUPPLY CHAIN
The Company has several systems in place to identify and assess potential risks in our supply
chain, mitigate these risks and protect whistle-blowers. These include:

o binding suppliers to ethical dealing clauses in all contract terms and conditions;
o holding regular review meetings with major commercial suppliers and brand partners which focus on the delivery of
goods and services in line with the terms of our agreement;
o invoking strict sanctions on suppliers who do not meet our performance expectations or uphold the terms of our
agreement (for example, any evidence of child labour results in the immediate delisting of a supplier); and
o use of an independent externally hosted Whistleblowing Hotline which all employees, workers and external
consultants/contractors working on behalf of Merlin are made aware of upon induction and encouraged to use
whenever appropriate, commissioned by the Company's Audit Committee which receives regular reports.

Furthermore, Merlin continually reviews its policies and procedures based on lessons learned from the above
initiatives, in order to proactively maintain an informed approach to preventing modern slavery in our society.
MERLIN ENTERTAINMENTS | 10
 TRAINING
All staff regularly involved in the procurement of goods and services understand the detail of our Ethical Dealing
Principles. Moreover, staff in the Central Procurement Team; MMM Project Directors and Managers; and Global
HR Directors and Recruitment Managers (i.e. those with the greatest exposure to modern slavery risks) received
modern slavery training in December 2022. It was rolled out to a wider audience, predominantly of procurement
and HR staff, in 2023. In 2024, we are focusing on geographical risk areas and delivering training in countries
perceived to be of a higher risk status, or subject to specific modern slavery legislation – these include China,
Malaysia, the UAE and Germany.

In addition to the policies and procedures that underpin monitoring and compliance, the Company also operates an
induction programme tailored to incorporate the Employee Code of Conduct and the relevant policies relating to specific
roles.

As our business expands, we are mindful of the increased risks relating to modern slavery associated with new market entry
and high-volume employment sectors such as accommodation, food and beverage operations and large capital development
projects. We ensure we abide by all local labour laws and that the policies that relate to modern slavery are an essential part
of any induction programme.

MERLIN ENTERTAINMENTS | MODERN SLAVERY STATEMENT 2023 11

 EFFECTIVENESS / PERFORMANCE REVIEW

In particular, during 2024 we intend to:

The Company understands that
modern slavery risk is continually o recruit a new Compliance Director whose remit will include managing and
evolving and will remain vigilant to overseeing Merlin’s international approach to modern slavery prevention, as well
slavery and human trafficking in its
supply chains. as enabling compliance with all relevant legal and regulatory obligations;
o deliver enhanced modern slavery training to Merlin personnel located in
We will always comply with local
countries where the risk of modern slavery is perceived to be higher and/or
legislation and adopt global standards
in the way we work with our people there is a specific need for additional training due to statutory developments
and our suppliers. (e.g. Germany);
o conduct a review of Merlin’s current anti-bribery and corruption policies and
We continue to monitor the
performance of our measures to procedures, to ensure that they are as robust as possible in respect of modern
detect and prevent modern slavery in slavery risks and potential exposures; and
our supply chains.
o complete the on-going modern slavery risk assessment which is focused on each
of Merlin’s key internal departments (previously this was an informal process).
MERLIN ENTERTAINMENTS | MODERN SLAVERY STATEMENT 2023 12
MERLIN
ENTERTAINMENTS

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and section 14 of the Australian Modern Slavery
Act 2018. It constitutes our modern slavery statement for the financial year ending 31 December 2023. This is a Group statement which
covers the subsidiaries that apply to the disclosure criteria of the UK Act, namely Merlin Attractions Operations Limited and Merlin
Entertainments (SEA LIFE) Limited. In respect of the Australian Act, it also covers Merlin Entertainments (Australia) Pty Ltd. It was
approved by the Board of Directors of Merlin Entertainments Limited on 30 June 2024 in its capacity as the principal governing body of
each reporting entity.