Legal
Modern Slavery Statement
Fiscal Year 2025 | Published: January 2026
Statement from the CEO
“At Harch Corp, we believe that the dignity of every human being is non-negotiable. Modern slavery, in all its forms — forced labor, human trafficking, debt bondage, and child labor — represents a fundamental violation of human rights that has no place in our operations or supply chain. As a Moroccan industrial conglomerate operating across seven verticals and multiple geographies, we recognize both our responsibility and our influence to drive positive change.
Our commitment goes beyond compliance. We actively seek to identify and eradicate modern slavery risks throughout our value chain, from the mines that supply our raw materials to the technology partners who power our digital infrastructure. We invest in due diligence, training, and remediation because we understand that building Africa's industrial sovereignty must be built on a foundation of respect for human rights.
This statement sets out the steps we have taken during the fiscal year 2025 to prevent modern slavery and human trafficking in our business and supply chains, and it reflects our unwavering commitment to continuous improvement.”
Amine Harch El Korane
Founder & Chief Executive Officer, Harch Corp S.A.
Our Business and Supply Chain
Harch Corp S.A. is a Moroccan multi-sector industrial conglomerate headquartered in Casablanca, Morocco. We operate across seven core verticals: AI data centers and intelligence infrastructure (1,798 GPU capacity), renewable energy generation and distribution (2GW+ Renewable Pipeline), cement and construction materials manufacturing, sovereign technology and cybersecurity services, strategic mining operations including phosphates and critical minerals, precision agriculture and vertical farming, and water infrastructure including desalination and treatment. Our supply chain spans multiple countries across Africa, Europe, the Middle East, and Asia, and includes raw material suppliers, equipment manufacturers, construction contractors, technology providers, logistics companies, and professional service firms. The diversity and scale of our operations present inherent modern slavery risks, particularly in labor-intensive sectors such as construction, mining, and agriculture, and in regions where regulatory frameworks may be less robust.
Policies and Due Diligence
We have established a comprehensive framework of policies and due diligence processes to identify, prevent, and mitigate modern slavery risks:
Supplier Code of Conduct
All suppliers and contractors are required to acknowledge and comply with our Supplier Code of Conduct, which explicitly prohibits forced labor, child labor, human trafficking, and all forms of modern slavery. The code requires suppliers to provide fair wages, safe working conditions, and freedom of movement for all workers.
Supplier Due Diligence
All new suppliers undergo a risk-based due diligence assessment before onboarding, which includes screening for modern slavery indicators, review of labor practices and working conditions, verification of recruitment agencies and labor intermediaries, assessment of geographic and sector-specific risks, and evaluation of the supplier's own policies and monitoring mechanisms. High-risk suppliers are subject to enhanced due diligence, including on-site audits conducted by independent third-party auditors.
Internal Controls
Our internal controls include rigorous recruitment and employment practices that verify the identity and legal right to work of all employees, prohibition of recruitment fees charged to workers, direct payment of wages to employees through transparent payroll systems, regular monitoring of working hours and conditions, and accessible grievance mechanisms for all workers, including subcontracted labor.
Risk Assessment
We conduct annual risk assessments to identify and evaluate modern slavery risks across our operations and supply chain. Our risk assessment methodology considers:
- —Sector-specific risks: Mining, construction, and agriculture are identified as higher-risk sectors due to the prevalence of migrant labor, informal employment practices, and hazardous working conditions.
- —Geographic risks: Operations and supply chains in regions with weaker labor protections, high levels of migration, or conflict-affected areas receive heightened scrutiny.
- —Labor provider risks: The use of third-party labor providers, recruitment agencies, and subcontractors introduces additional risks that are managed through enhanced due diligence and contractual safeguards.
- —Raw material risks: The sourcing of critical minerals and raw materials, particularly from artisanal and small-scale mining operations, carries inherent risks that require specialized monitoring and traceability measures.
Key Actions Taken
During fiscal year 2025, we took the following actions to combat modern slavery in our operations and supply chain:
Conducted 47 on-site supplier audits across all seven verticals, with 12 audits specifically focused on high-risk suppliers in the construction and mining sectors. Identified 3 non-conformities related to working hours documentation and took immediate corrective action.
Implemented a digital supply chain traceability platform for our mining and agriculture verticals, enabling end-to-end visibility of labor practices from raw material extraction to final delivery.
Terminated relationships with 2 suppliers who failed to demonstrate adequate controls against modern slavery after a remediation period. These terminations were conducted in accordance with our responsible exit protocol to minimize adverse impacts on workers.
Established a dedicated Human Rights and Supply Chain Integrity team within the Compliance Office, staffed with specialists in labor rights, supply chain management, and social auditing.
Adopted the Employer Pays Principle across all our operations, ensuring that no worker bears the cost of recruitment to obtain employment with Harch Corp or its suppliers.
Training and Awareness
During fiscal year 2025, we delivered modern slavery awareness training to 100% of our employees and key contractor personnel. Training programs included mandatory e-learning modules for all employees on identifying and reporting modern slavery, specialized in-person workshops for procurement and supply chain teams, targeted training for site managers and supervisors on labor rights and worker welfare, training for HR professionals on ethical recruitment practices and the Employer Pays Principle, and awareness sessions for senior leadership on emerging regulatory requirements and best practices. In total, over 2,800 hours of training were delivered, and we achieved a 96% completion rate across all mandatory modules.
Effectiveness Measurement
We measure the effectiveness of our actions to combat modern slavery through the following key performance indicators:
| Indicator | FY 2025 Target | FY 2025 Actual |
|---|---|---|
| Supplier audits completed | 40 | 47 |
| High-risk suppliers audited | 100% | 100% |
| Employee training completion | 95% | 96% |
| Non-conformities identified and resolved | N/A | 3 identified, 3 resolved |
| Grievances related to labor practices received | N/A | 7 received, 7 investigated |
Next Steps
Looking ahead to fiscal year 2026, we plan to:
- —Expand our digital supply chain traceability platform to cover 100% of our tier-1 and tier-2 suppliers across all verticals.
- —Implement worker voice technology in our mining and agriculture operations to enable direct and anonymous feedback from workers.
- —Commission an independent third-party assessment of our modern slavery due diligence framework and implement its recommendations.
- —Enhance collaboration with industry peers, civil society organizations, and government agencies to share best practices and drive systemic change.
- —Conduct a comprehensive review of our recruitment agency framework across all operations, with particular focus on cross-border labor migration pathways.
Approval and Signature
This Modern Slavery Statement has been approved by the Board of Directors of Harch Corp S.A. and is published in accordance with the UK Modern Slavery Act 2015, Section 54, the Australian Modern Slavery Act 2018 (Cth), and our voluntary commitment to transparency under the Kingdom of Morocco's legal framework.
Amine Harch El Korane
Founder & Chief Executive Officer
Harch Corp S.A.
Date: January 2026
Published: January 2026 | This statement is governed by the laws of the Kingdom of Morocco.