Modern Slavery Statement

ICNC people (Iconic People Holland B.V.) believes that modern slavery and human trafficking have no place in our business or our supply chain. We mobilise skilled technical specialists across international borders — a sector where labour exploitation risk is real and where the responsibilities of the employer cannot be delegated or ignored.

This statement sets out our commitment to preventing modern slavery and human trafficking in our own operations and across the three tiers of our supply chain. It is published voluntarily. We believe that transparency on these matters is not a compliance exercise — it is a condition of operating with integrity in our sector.

ICNC people is a Dutch manpower consulting firm specialising in the cross-border mobilisation of skilled technical specialists into sectors facing structural workforce shortages in the Netherlands. We operate as a licensed Dutch labour intermediary (Waadi-registered) and, where we engage workers directly, as their employer of record.

Our sectors: Energy & Grid, Engineering, Data Centers, Life Sciences, Cybersecurity and Semiconductor.

Our sourcing geographies: the Philippines, India, Indonesia, Eastern Europe & Balkans, and Africa & MENA.

Our service lines: Employer of Record, Permanent Placement, Workforce Compliance and Immigration services.

We are incorporated in Amsterdam as Iconic People Holland B.V. (KvK 87347652) and are subject to Dutch law, EU labour regulations, and the ILO Core Conventions.

We recognise that cross-border technical staffing carries inherent modern slavery and trafficking risk. Our honest assessment of where that risk sits:

Tier 1 Our own operations

Risk is low but not zero. As employer of record, we have direct control over employment contracts, wages, housing arrangements, and working conditions. The fair employer commitments in our operating model — zero fee deductions from worker wages, written contracts before start date, transparent housing, no debt bondage — are structural protections, not aspirational policies.

Tier 2 Sourcing and deployment partners

Risk is elevated. In-country recruitment partners, local sourcing agents, and placement intermediaries in our sourcing geographies operate in environments where labour exploitation is more prevalent. We Tier 2 is the primary focus of our due diligence programme.

Tier 3 Client supply chains

Risk is indirect. We expect our clients to operate to equivalent ethical labour standards and will include this expectation in our client agreements. Where we become aware of practices inconsistent with these standards at a client site, we will address this directly.

Tier 1 — Our own operations

The following commitments apply to every worker mobilised by ICNC people, without exception:
— Zero recruitment fee deductions from worker wages — ever. Workers are never charged for their placement, visa processing, or onboarding.
— Written employment contract in a language the worker understands, issued and signed before the start date.
— Wages paid correctly, in full, and on time — directly to the worker’s own bank account.
— No withholding of identity documents at any point in the process.
— Housing support is optional, disclosed, quality-controlled, and priced transparently. Workers retain the right to arrange their own accommodation at all times.
— Workers may raise concerns directly with ICNC people — not only through the client site. The speak-up channel is independent of the client relationship.
— 30-60-90 day onboarding and integration support, with direct contact maintained between ICNC people and each deployed worker throughout the assignment.
— Full compliance with ILO Core Conventions on forced labour (No. 29 and No. 105), child labour (No. 138 and No. 182), and freedom of association (No. 87 and No. 98).

Tier 2 — Sourcing and deployment partners

All sourcing and deployment partners are subject to the following commitments:
— All sourcing and placement partners are subject to a formal vetting process before engagement. This includes assessment of their recruitment practices, fee structures, worker treatment standards, and compliance with applicable local and international labour law.
— Contractual commitments are required from all partners: no recruitment fees charged to workers, no document retention, compliance with ILO standards, and cooperation with any audit or investigation.
— We do not engage with partners who cannot demonstrate equivalent ethical recruitment standards, regardless of the cost or time implications.
— We conduct periodic partner reviews and, as our operations scale, will introduce third-party assessments. Findings and corrective actions are documented.

Tier 3 — Clients

We expect our clients to operate workplaces and supply chains that are free from forced labour, human trafficking, and child labour. We will:
— Include ethical labour standards expectations in our client service agreements.
— Reserve the right to withdraw workers from a client site where we have reasonable grounds to believe a worker’s safety, dignity, or rights are at risk.
— Engage constructively with clients on any concern raised — whether by a worker, by ICNC people personnel, or by a third party.

Our due diligence mechanisms include:

— Pre-deployment checks: identity verification, right to work checks, and immigration compliance for every worker before their start date.

— Onboarding form: each deployed worker completes a structured onboarding form (GDPR-classified) confirming their personal details, bank account, and consent to data processing. This process creates a direct relationship between ICNC people and the worker, independent of any sourcing intermediary.

— Direct worker contact: ICNC people maintains direct communication with each deployed worker throughout the assignment, not mediated through the client or a local partner.

— Speak-up channel: workers can raise concerns at any time by contacting speak-up@icncpeople.com. Reports are handled confidentially and will not result in retaliation.

We continue to build our due diligence programme, including worker satisfaction check-ins and — as our deployed workforce scales — third-party social audits of sourcing geographies.

ICNC people’s team is briefed on modern slavery risk as part of induction. All staff involved in sourcing, onboarding, or managing worker deployments are expected to be familiar with:

— The indicators of forced labour and human trafficking in an international staffing context

— ICNC people’s zero-tolerance position on recruitment fee charging and document retention

— How to escalate a concern internally or through the speak-up channel

As we engage external sourcing partners, we will extend training and awareness requirements to relevant partner contacts.

Anyone — worker, client, partner, or third party — who has a concern about modern slavery, human trafficking, or labour exploitation in connection with ICNC people’s operations is encouraged to come forward.

Speak-up channel: speak-up@icncpeople.com All reports are handled confidentially. There will be no retaliation against anyone who raises a concern in good faith.

Concerns may also be reported to the Dutch labour inspectorate (Nederlandse Arbeidsinspectie) at nlarbeidsinspectie.nl, or, in the case of suspected trafficking, to CoMensha (the Dutch national coordination centre against human trafficking) at comensha.nl.

This statement is published voluntarily. ICNC people is incorporated in the Netherlands and its primary regulatory framework is Dutch and EU law. Relevant regulations include:

— ILO Core Conventions on forced labour, child labour, and freedom of association

— Dutch Civil Code (Burgerlijk Wetboek) — employment law obligations

— Waadi (Wet allocatie arbeidskrachten door intermediairs) — labour intermediary regulation

— EU Forced Labour Regulation (Regulation 2024/3015) — entering into application from 2027

— Dutch Wet zorgplicht kinderarbeid — due diligence obligation on child labour

We monitor developments in Dutch and EU forced labour due diligence legislation and will update our practices and this statement as requirements evolve.

This statement is reviewed regularly and updated as our operations develop — particularly as we establish sourcing partner relationships, scale our deployed workforce, and build out our due diligence programme. Material updates will be published at icncpeople.com.

Damiaan Sprenger
Partner, ICNC people
On behalf of Iconic People Holland B.V.

This statement has been reviewed and approved by Damiaan Sprenger, Partner, on behalf of Iconic People Holland B.V.