ZeniMax Europe Limited’s Statement on U.K. Modern Slavery Act
1. INTRODUCTION
1.1. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015(the “Act”)
and constitutes ZeniMax Europe Limited’s modern slavery and human trafficking statement
for the financial year ending 31 December 2022
2. ORGANISATION’S STRUCTURE & BUSINESS ACTIVITY
2.1. ZeniMax Europe Limited (“ZeniMax Europe”, “We”, “Our”) is a UK limited liability company,
a wholly owned subsidiary of ZeniMax Media Inc. which has its headquarters in the USA.
ZeniMax Europe’s principal business activity is the marketing, publishing and distribution ofinteractive entertainment software and original video game content developed by ZeniMax
Media Inc. and its subsidiaries (collectively referred to as “ZeniMax Media”).
2.2. ZeniMax Media’s business is organised by territory across North America, Canada, Europe,
Australia, Asia, and until March 2022, also Russia. ZeniMax Europe has established andoperates through subsidiary companies in a number of these territories, and also via local
partners.
2.3. This Statement is made on behalf of ZeniMax Europe’s operations in the UK although its
principles, policies and the processes referenced herein are shared by our overseas
subsidiaries.
3. OUR SUPPLY CHAIN, RISK ASSESSMENT & DUE DILIGENCE PROCESSES
3.1. ZeniMax Europe’s supply chain predominantly consists of suppliers and partners based in theUK and overseas.
3.2. The nature of ZeniMax Europe’s business does not centre on the manufacture or productionof hardware nor does ZeniMax Europe require services directly or via recruitment agencies
that are typically performed by migrant workers. While we currently believe the risk ofslavery and human trafficking within our supply chain to be low, ZeniMax Europe remains
committed to the exclusion of modern slavery or human trafficking from our supply chains
or in any part of our business. We only work with reputable suppliers, many of whom aresubject to the Act, and carry out internal risk assessments and due diligence with oursuppliers.
3.3. ZeniMax Europe implements a zero-tolerance policy with its suppliers and partners in respectof slavery and human trafficking. Our terms of business require each supplier or partner tocomply with and procure from its affiliates compliance with the principles of the Modern
Slavery Act 2015.
4. OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING AND TRAINING
4.1. Our internal policies continue to affirm the importance we place on fair treatment andintegrity within the workplace and in all our business relationships. The policies communicate
the risk assessment factors to be considered and protocols to be implemented to detect therisk of slavery and/or human trafficking taking place anywhere along our supply chains.

4.2. ZeniMax Europe’s internal employee policies require all staff to act responsibly,
professionally and ethically and to ensure at all times they are complying with the law,encouraged to report concerns of misconduct and have appropriate sanctions in place for
instances of non-compliance.
TRAINING
4.3. ZeniMax Europe provides its staff with training relevant to their respective roles andcontinues to engage in discussion and address slavery & human trafficking issues throughdirect dialogue with stakeholders, remaining conscious of future training opportunities for its
personnel.
5. FURTHER STEPS
5.1. ZeniMax Europe is satisfied that it is appraised of its obligations under the Act and willcontinue to give the prevention of slavery and human trafficking importance in its business
operations.
This statement on U.K. Modern Slavery Act has been approved by the Board of Directors of ZeniMax
Europe Limited.