Konami Digital Entertainment B.V.

Introduction

This statement outlines the steps Konami Digital Entertainment B.V. ("Konami") has taken during the year ending March 2025 to prevent human trafficking and modern slavery in its business and supply chains, pursuant to Section 54, Part 6 of the Modern Slavery Act 2015.

Konami is a leading video game and trading card game publisher and distributor operating in the European gaming industry. As part of the Konami Group of Companies, with its parent company being KONAMI GROUP CORPORATION headquartered in Tokyo, Japan, the Group operates across 25 consolidated subsidiaries and employs 9,038 people worldwide as of March 31st, 2025.

Recognizing modern slavery, forced labour, and human trafficking as significant global issues, Konami maintains a zero-tolerance approach and is committed to ethical conduct and integrity in all its business dealings and relationships.

Policies and Practices

Konami's internal policies relevant to this issue include:

• Employee Handbook

  This handbook prescribes an environment where employees act ethically, honestly, and with integrity. It has been updated to provide accurate policies, such as anti-bribery, and is easily accessible to all Konami employees.

• Whistleblowing Policy

  Employees are encouraged to report suspected violations of law or company policy, including human rights violations like modern slavery, especially when direct reporting to a supervisor is not feasible. All reports are fully investigated, and appropriate remedial actions are taken.

• Anti-slavery and human trafficking policy

  Introduced in May 2019, this policy confirms Konami's non-tolerance for any abuse of human rights within its business or supply chains. Allegations are addressed promptly and with utmost importance. This policy is provided to all new employees during their induction process.

• Konami Group Code of Business Conduct and Ethics

  This code illustrates Konami's policies on key company matters, including the prohibition of bribery, respect for human rights, fair dealings with suppliers, and fostering a healthy working environment.

Due Diligence

Konami's primary exposure to modern slavery and human trafficking is within its manufacture and product supply chain.

Konami works with a limited number of suppliers for trading card game supplies and first-party video gaming platforms, collectively referred to as "Product Suppliers".

A risk-based questionnaire is sent annually to Product Suppliers to identify any areas of concern in their manufacturing operations and supply chains. Konami seeks commitments from Product Suppliers to implement mirroring policies and processes for identifying and addressing modern slavery risks.

Failure by a third party to meet expectations or demonstrate willingness to make suggested changes may result in cessation of engagement.

Workplace Measures

• All Konami employees are bound by written employment contracts.
• Konami utilizes credible employment agencies for sourcing employees.
• Recruitment agencies are required to adhere to the same anti-slavery precautions as Konami.

Training

The Anti-Slavery and Human Trafficking Policy is a mandatory component of the induction and training phase for all new Konami employees.

Summary

Konami acknowledges the ongoing and potentially increasing risk of modern slavery globally. The company is committed to its threefold approach to mitigating this risk in the coming year:

• Education and Training

  Ensuring modern slavery is a conscious consideration for all employees, encouraging the reporting of suspected human rights violations.

• Continuous monitoring of risk

  Konami will revisit its questionnaire with Product Suppliers annually to identify any new areas of risk.

• Accountability

  Konami will be accountable for its business relationships, working progressively to eliminate vulnerabilities in its business and supply chains. Suspected or identified modern slavery or human rights abuses will be met with prompt corrective action and collaboration with suppliers to eliminate future risk.