Introduction

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015and sets out the steps that Vivo Energy Limited and its subsidiaries and affiliates (“Vivo Energy”) have taken to prevent modern slavery in their business and supply chains. This statement covers the period from 1 January 2025 to 31 December 2025.

 

Our commitment

Vivo Energy strongly supports the elimination of all forms of modern slavery. Such exploitation is contrary to our core values of Safety, Excellence, Caring, Respect and Integrity, which are crucial to our success and growth and to achieving our vision to be Africa’s leading and most respected energy business.

We are committed to respecting, upholding and applying the highest human rights and ethical standards across the economies and societies in which we operate. Our approach is guided by the ten Principles of the UN Global Compact, with which Vivo Energy complies.

 

About Vivo Energy

Vivo Energy is a market-leading pan-African distributor and retailer of Shell and Engen-branded fuels and lubricants. We source, distribute, market and supply these products to Retail and Commercial customers across Africa. We also have a growing non-fuel retail offering. At the end of 2025, our Retail network comprised around 4,000 service stations across 28 African markets. We also export lubricants to more than 10 additional markets.

 

Our policies

At Vivo Energy we recognise that robust policies serve as a foundation for protecting and upholding human rights.

Respect for human rights is embedded in our Code of Conduct and General Business Principles (all available on our website). These policies underpin everything we do and are the foundation of our business. It further recognises the responsibility to conduct business as responsible corporate members of society. Both the Code of Conduct and General Business Principles address our commitment to combatting modern slavery and human trafficking.

We require our business partners to comply with our Third-Party Code of Conduct, which sets clear standards on ethical behaviour, including bribery, corruption, the prohibition of child labour and unfair labour practices.

We regularly review our policies, manuals and frameworks to ensure they remain relevant, fit for purpose and effective.

 

Assessing and managing risk

We have developed and implemented various measures to address risks of modern slavery arising in parts of our business and supply chains that we consider represent a higher risk.

 

Counterparty screening

We have a detailed counterparty screening process in place, which is formalised in the Vivo Energy Know Your Counterparty (“KYC”) policy. The screening process gives us confidence that we know who we are doing business with and that the ethics and values of our counterparties align to our core values. As part of the screening process, we request new counterparties to agree to a compliance statement, which communicates our expectations on modern slavery, and highlight the whistleblower hotline should the counterparty witness or become aware of any violation of the General Business Principles, Counterparty Code of Conduct or any other unethical or illegal/criminal act. We further require the counterparty to confirm they are not aware of any instances of modern slavery linked to their business and request that they take steps to communicate our expectations to any sub-contractors or agents with which they engage.

 

Anti-bribery management

Vivo Energy has been ISO:37001(2016) compliant since 2023. ISO 37001 is the international standard for Anti‑Bribery Management Systems and provides a structured framework to enable organisations to prevent, detect, and respond to bribery across internal operations and third‑party relationships. As part of this, the operating units within the group are audited on their processes and procedures regarding policy adoption, education and whistleblower practices. Through this we are comfortable that appropriate steps have been taken to ensure awareness of the whistleblower hotline and understanding of our policies.

As part of our Anti Bribery Management System, special site inspections, which includes identifying elements of modern slavery at our retail sites, are conducted. In 2025, we conducted assessments in six countries.

 

Procurement practices

Our procurement practices are governed by a structured Contracting and Procurement Procedures Manual. This Manual applies to the supply of all non-hydrocarbon goods or services and sets out clear procedures regarding supplier evaluations prior to embarking on business relationships. We evaluate and select our suppliers and vendors based on various criteria. This includes considerations relating to suppliers’ abilities to uphold human rights within their own operations.

 

Contract management

All our contracts with suppliers incorporate appropriate legal and regulatory obligations, including compliance obligations with respect to the Modern Slavery Act where applicable.

Furthermore, in our Downstream retail business, agreements with retailers and dealers require such counterparties to abide by all relevant legislation.

 

Supply and distribution

Across our group, we conduct comprehensive audits before engaging any haulier companies. This is followed by a further audit once a contract is in place. These audits and assessments conducted include considerations of the haulier’s training practices and the working conditions of the drivers, ensuring alignment with our health and safety and ethical standards.

All vessels involved in our supply chain undergo a comprehensive vetting process to ensure full compliance with maritime, safety, and regulatory standards.

 

Retail

In 2025, the Combatting Modern Slavery guidelines were formally rolled out in South Africa, our biggest operating unit, following our acquisition of South African oil company, Engen, in 2024. As part of the rollout, Retail Dealers were required to:

  • Review and familiarize themselves with the Combatting Modern Slavery Guidelines;
  • Sign a formal undertaking confirming awareness, commitment and compliance;
  • Promote visible awareness among site managers and employees;

  • Report any concerns through the prescribed escalation channels and whistleblowing line.

     

Due diligence

Internal audit

Annually, a sample of third-party contracts and employment contracts are selected for testing, to ensure that they are compliant with laws and regulations and to ensure that the terms of the contracts are upheld.

 

Grievance mechanisms

Reporting violations or suspected violations of the General Business Principles, Counterparty Code of Conduct or any other ethical norms or laws is essential to protecting our reputation and the value of our brand.

To ensure all concerns are addressed, we engaged an independent firm to operate a global whistleblowing helpline. The helpline is available to all Vivo Energy employees, contract staff and third parties who have a business relationship with us and is accessible 24 hours a day, 365 days a year and supports 24 languages including English, French, Portuguese, Dutch, and Arabic.

A specific reporting category is included in the helpline to ensure that modern slavery concerns are promptly identified and escalated to the Chief Legal and Compliance Officer. All such concerns are investigated promptly and if founded, recommendations to rectify and address the concerns are treated with utmost urgency.

Whistleblowing helpline posters are placed at all our retail sites to create awareness of the mechanism available for retailers’ employees and/or third parties to report any concerns.

In 2025, our due diligence processes did not uncover any substantiated cases of modern slavery. We continue to assess indicators throughout the year.

 

Training and awareness

Mandatory staff training courses covering the Code of Conduct and General Business Principles are provided to all employees annually. Completion of all training courses is monitored by our Compliance Function.

All new employees must complete an induction programme, which explains our policies and helps them integrate into the organisation quickly and comprehensively. The induction programme includes training in relation to our Code of Conduct.

Enhanced modern slavery training is provided to all retail/supply and distribution staff to equip them in identifying and reporting modern slavery concerns at each of their retailer/transporter engagements.

In addition to the above, special campaigns have been launched to provide our Human Resources teams, retailers and transporters/hauliers with modern slavery guidance awareness and training This entailed raising awareness on ‘red flags’ and how to report any instances of concerns relating to modern slavery. A specific focus was placed on getting the message across to the customer champions on our service station forecourts and drivers who transport our products, as although they are not directly employed by us, they are considered our most vulnerable for abuse.

 

Looking forward

Our enduring commitment to Vivo Energy’s values means that we will continue to seek ways in which we might improve our capacity to identify and deal with modern slavery risks in all aspects of our business and supply chains.

This statement has been approved by the board of directors of Vivo Energy Limited.

 

Stan Mittelman
CEO
Vivo Energy Ltd

18 March 2026