Pulsar : Annual Report 2025

Annual Report 2025

Year ended 30 November 2025

Pulsar Group is a market leading audience intelligence business.

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We deliver audience intelligence, reputation management, and marketing and communications insight for blue chip enterprises around the world.

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Contents

Business Overview 07

Chairman's Statement 08

Timeline 14

Ыe Group's audience intelligence strategy 16

Global scale 18

Investing in people to thrive 20

Strategic report 23

• Risk management 27

• Stakeholder engagement - Section 172(1) statement 33

Environmental, Social and Corporate Governance 39

Directors and advisers 40

Ыe Board 41

Chairman's corporate governance statement 45

Corporate governance 47

Environmental, social and governance report 61

Task Force on Climate Related Financial Disclosures 69

Audit committee report 77

Remuneration committee report 83

Directors' report 95

Independent auditor's report 103

Financial Statements 115

Consolidated statement of comprehensive income 116

Consolidated statement of financial position 118

Consolidated statement of changes in equity 120

Consolidated statement of cash flow 124

Notes to the consolidated financial statements 127

Company statement of financial position 164

Company statement of changes in equity 166

Notes to the Company financial statements 168

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Chairman's statement

2025 was a year in which artificial intelligence moved decisively from the realm of opportunity into the fabric of operational reality for professionals in the communications, public relations, public affairs, and marketing industries.

For organisations navigating a world of fragmented media, geopolitical uncertainty and accelerating information complexity, the ability to harness AI

as a strategic capability has become a defining characteristic of those who lead and those who lag. Pulsar Group sits firmly in the former category and is set to benefit disproportionately from the accelerated interest to embed this technology into workflows for the marcomms industry.

From the national political cycles and continuing conflicts reshaping global alliances, to landmark regulatory shifts in AI governance and data privacy, the environment our clients operate in has never demanded more of their marcomms intelligence. Audiences

are more discerning, narratives move faster, and the consequences of being caught unprepared have rarely been more severe. It is precisely in this context that Pulsar Group's platform, built around real-time audience intelligence, AI-powered insight and trusted decision support, has become ever more vital to the organisations we serve.

Ыrough our embedded AI capabilities, our platform does not simply monitor the world; we interpret

it, anticipate evolutions and help our clients craft, optimise and follow through on their omnichannel communications and campaigns for maximum impact.

Christopher Satterthwaite Non-Executive Chairman

AI AS CORE ARCHITECTURE

Ыe marcomms industry stands at an inflection point. Generative AI has already fundamentally altered how information is created, distributed and consumed and will continue to reshape the media landscape. Large language models are now part of how millions of people search, research and form opinions. Ыe boundaries between authentic voice and synthetic content, between signal and noise, are increasingly contested. In this environment media and audience intelligence are no longer a supporting function: rather, they are mission-critical infrastructure.

At Pulsar Group, we have been building for this moment for several years. Long before generative AI entered mainstream awareness, we were deploying machine learning and automation to power narrative detection, real-time sentiment benchmarking, and scalable media analysis. We have a coherent suite of AI capabilities designed for the specific professional contexts in which our clients operate, and addressing a distinct challenge

that has long frustrated the people who depend on communications intelligence to do their jobs.

What distinguishes our approach from the rest of the space is that we have not bolted some AI capabilities onto existing products. We have instead built our capabilities around AI, with a deliberate focus on utility, explainability and accountability. Because the professionals who use our platforms are accountable for the decisions they make, the intelligence we provide must be traceable, trustworthy and grounded in evidence.

THE FUTURE OF THE PR & COMMS PROFESSIONAL

Ыe AI revolution, marked by the rise of agentic browsers and AI companions that summarise the web and mediate truth, is fundamentally redefining the PR and Communications professional's role. Ыis shift is moving the function to the very centre of how a brand is understood. PR and Comms professionals are becoming the primary architects of brand reputation, emotional connection, and narrative coherence, tasked with influencing both human audiences and the intelligent agents that interpret what those audiences see. Ыe focus is shifting from broad message distribution to earning relevance by shaping the credible raw material that both people and AI models use to determine

who is trustworthy: from media authority, to human storytelling, and third-party advocacy.

Ыis is not only our view. Gartner's predictions for Chief Communications Officers (CCOs) in 2026 make it clear how communications is now core business infrastructure, and the skillset it demands - from

narrative intelligence, to answer engine optimisation, and real-time reputation monitoring, sits squarely in the domain of PR and Comms rather than marketing or paid media. For CCOs and their teams, the question is no longer whether their function is strategic, but whether they have the intelligence infrastructure to operate at the speed and scale this new environment requires.

Ыis new environment mandates a strategic shift toward confidence building, organised around five interconnected responsibilities.

• Earned Proof: building trust on what an organisation can demonstrably show, not what it claims.

• Reputation Agility: detecting early signals and responding with clarity before misinformation enters AI-generated summaries.

• Human Authenticity: amplifying the voices of employees, customers, and communities whose credibility polished messaging cannot replicate, and whose distributed signals AI systems increasingly interpret as markers of trust.

• Curated Discoverability: ensuring key facts are structured and technically accessible so AI systems can find, interpret, and cite them accurately.

• Cross-Functional Integration: aligning what communications says with what product, legal, and data teams actually do, because AI surfaces contradictions that audiences once had to work to find, and incoherence is no longer a slow reputational risk but an immediate one.

We expect the evolution of the function to unfold in three stages. Most organisations are currently engaged

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Chairman's statement

in Narrative Stewardship, mapping how stories circulate through AI models and social platforms and beginning to build the earned proof and human authenticity

that ground those narratives. Ыis will progress to Reputation Architecture over the next 12 to 24 months, where PR teams become responsible for curating the organisation's authoritative content of record, the factual and emotional material intelligent systems use to build understanding, while embedding discoverability and cross-functional integration into how that content is produced and maintained.

Ыe final stage, Influence Intelligence, within two to five years, places PR and Comms in a central intelligence role. Professionals will monitor how the brand is represented not just in headlines but in the summaries and answers generated by AI systems, tracking cited sources, spotting misinformation, deploying reputation agility at machine speed, and using predictive tools to anticipate emerging issues. By aligning human trust with machine interpretation and using data-driven frameworks, the PR professional transitions from communicator to central strategist who advises leaders, predicts narrative shifts, and manages reputation with the same seriousness applied to financial or operational performance.

THE FUTURE OF THE MARKETING PROFESSIONAL

If AI is rewriting the rules of credibility for PR and Comms, it is doing something equally profound but structurally different to the marketing profession. Particularly for social, content, and brand marketers, and for the strategists and researchers who inform their decisions, the transformation is about the collapse of the traditional feedback loop between audience

understanding, creative execution, and performance measurement. AI is compressing that cycle from weeks to hours, and in doing so it is exposing a gap between organisations that still treat audience insight as a periodic input and those building it into a continuous operating system.

Ыe immediate consequence is the obsolescence of static segmentation. For a generation, marketers have relied on demographic and attitudinal clusters refreshed quarterly or annually to guide targeting, messaging,

and media planning. Ыat model cannot survive contact with an accelerating environment in which audience behaviours, cultural references, and platform dynamics shift week to week.

Ыe marketers gaining ground are those who treat segmentation as a living, real-time layer, continuously recalibrated against actual content engagement, search behaviour, and community formation, rather than a

fixed map drawn from a single wave of research. Market researchers, in particular, face the challenge of evolving into the architects of these dynamic intelligence systems. Content and brand marketers, meanwhile, confront a different challenge. Generative AI has made content production nearly frictionless, which means volume is no longer a competitive advantage. Ыe discipline is shifting from creation to orchestration: understanding which formats, voices, and cultural contexts produce resonance with specific audiences

at specific moments, and deploying AI to test, adapt, and optimise at a speed that manual workflows cannot match. Brand strategy in this context becomes less about owning a singular message and more about maintaining coherence across an exponentially larger

surface area of touchpoints, many of which the brand does not directly control.

We see this evolution unfolding in three stages, distinct from but contemporaneous with the shifts in PR and Comms. Most marketing organisations are currently

in a phase of Augmented Execution, using AI to accelerate production, automate reporting, and scale personalisation within existing strategic frameworks. Ыe next stage, Continuous Audience Intelligence, emerging over the next 12 - 24 months, will see the integration of real-time behavioural and cultural signals directly into campaign planning and creative development - collapsing the gap between research,

strategy, and activation into a single adaptive workflow. Strategists and researchers who can operate across this compressed cycle will become the most valuable people in the function. Ыe final stage, Predictive Brand Management, within two to five years, will see marketing leadership equipped with AI systems that model how shifts in audience composition, cultural sentiment, and competitive positioning are likely to affect brand equity before they manifest in traditional metrics. At this point, the marketer's role is no longer reactive optimisation but forward-looking stewardship of commercial relevance, a discipline as rigorous and consequential as any in the organisation.

While a substantial overlap exists across the marcomms industries, a critical distinction between this trajectory and the parallel evolution of PR and Comms is one of orientation. Where PR is moving toward the governance of trust and narrative integrity in an AI-mediated information environment, marketing is moving toward the mastery of audience dynamics and resonance

within that same environment. Both functions depend on intelligence infrastructure, which is precisely why Pulsar Group has built its platform to serve each with equal depth.

In all of this, trust remains the central variable.

Ыe organisations that will thrive are those that earn credibility with their audiences, not through volume of communication, but through the quality, authenticity and relevance of what they say and how they say it.

Our platform is built to support exactly that kind of purposeful, evidence-led communication.

As evidenced in the following section on product innovation in this report, Pulsar Group is bringing to market solutions that directly address many of those shifts and evolutions, with the goal of arming

marcomms professionals with the intelligence tools they need to create that trust.

STRATEGIC EXECUTION

Our product innovation does not exist in isolation.

It is enabled by, and in turn reinforces, the operational transformation that has been the hallmark of the Group's recent years. Ыe rebrand to Pulsar Group marked the culmination of a multi-year integration journey, bringing our technology, talent and operational footprint under a single brand and a coherent vision.

Ыe efficiencies unlocked by platform consolidation and operational streamlining are what allow us to invest with conviction in the AI capabilities that differentiate us commercially and what gives us confidence in

the sustainability and scalability of the model we are building.

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Chairman's statement

Our PR & Communications division remains the cornerstone of this strategy, with commercial metrics that provide the stability and predictability we need to invest in the next phase of innovation. Ыe Group's

focus on profitable, scalable growth, disciplined capital allocation and long-term value creation for shareholders remains unchanged.

FINANCIAL PERFORMANCE

Ыe 2025 financial year was a pivotal period during which we successfully balanced accelerating organic growth with a fundamental realignment of our global operating model. Total Group ARR at year-end increased to £64.5 million, representing a £3.9 million increase on a constant currency basis. Ыis growth velocity is nearly double that achieved in FY24, fuelled largely by our ability to secure group-wide mandates with global enterprise leaders who are standardizing on Pulsar for strategic intelligence.

To ensure this growth remains scalable and profitable, we completed a comprehensive structural cost-rationalisation programme during the 2025 calendar year. Ыis initiative delivered over £7.0 million in annualised savings, primarily through automation and the decommissioning of duplicate legacy technology. During this transition, overall Group headcount was reduced by 22%. In May 2025, as part of the global operating realignment programme, Pulsar Group raised

£2.9m net of expenses in funding.

Ыe scale of this operational transformation resulted in significant non-recurring administrative expenses during FY25, primarily related to restructuring and

integration costs. As detailed in the Financial Review on page 24 and Note 5 on page 141. Ыe non-recurring salary costs include the year to date costs and redundancy costs of roles that either exited during 2025 or which were already identified before the year end to exit during 2026. Ыe Board considers these one-off costs as a necessary investment to unlock the enhanced operating leverage now visible across the business.

Ыese efficiencies drove a marked improvement in our underlying profitability, with Adjusted EBITDA increasing to £10.4 million (2024: £9.3 million) and Adjusted EBITDA margin rising to 17% (2024: 15%).

Ыe Group has entered the 2026 financial year at a clear inflection point in its cash generation profile. Ыe structural changes made in 2025 are now delivering tangible bottom-line results, with the Group achieving an Adjusted EBITDA of £2.8 million for the first three months of FY26 compared to £1.8 million for the comparative period in FY25.

Trading remains positive for FY26, with ongoing ARR expansion and an encouraging enterprise pipeline to support the Board's ARR growth expectations for the year.

Ыis operational momentum has enabled rapid de-leveraging since the period end. Our net debt position, which stood at £5.6 million at 30 November 2025 following the peak of our restructuring spend, improved substantially to £3.5 million as at 23 April 2026 through improved free cash flow.

To support our next phase of global expansion, we successfully refinanced the Group's lending facilities in on 30 April 2026. We have secured a new, three-year, £8.0 million facilities with HSBC Innovation

Banking, replacing the £6.0 million in place at year-end. Ыese new facilities, comprising amortising and non-amortising loans of £6.0 million alongside a £2.0 million revolving credit facility (RCF), provide the Group with enhanced financial headroom and a flexible capital structure.

With a leaner, AI-led operating model and a strengthened balance sheet, the Board is confident in the Group's ability to deliver sustainable, profitable growth throughout 2026 and beyond.

IN SUMMARY

Despite the tough macroeconomic environment, 2025 has demonstrated, with clarity, that artificial intelligence is not a future consideration for the communications and media intelligence industries, it is the present competitive battleground. Pulsar Group has responded to this reality not with incremental adaptation, but with foundational innovation that is purposeful, explainable and genuinely useful to the professionals who depend on it.

Ыrough Lumina, Narratives AI, Crisis Oracle and CLEAR, we have built a coherent decision infrastructure for a world defined by information complexity, reputational risk and the pervasive

influence of AI on public discourse. Each product addresses a real and specific professional need. Together, they represent innovation that helps our

clients understand not just what is happening in their communications environment, but why it is happening, and what to do about it, with speed, confidence

and integrity.

As we look ahead, our focus remains on execution, margin expansion and the disciplined deployment of capital in areas where we have proven product-market fit and the clearest pathway to sustainable growth. Ыe Group's unified platform, growing client base across public and private sectors, and

deepening AI capabilities position us well to continue building shareholder value while serving the clients who trust us to help them navigate an increasingly complex world.

I want to close by acknowledging the talent and commitment of the teams across Pulsar Group who have made this progress possible. Building genuinely differentiated AI capabilities, while simultaneously transforming our operational model and delivering for clients, is no small undertaking. Ыe quality of what we have produced this year is a testament to the people behind it.

Christopher Satterthwaite,

Chairman

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Timeline

pre 2017

2017 - 2019

2020 - 2022 2023 onwards

Joanna Arnold appointed Chief Executive Officer

Before joining the Group, Joanna's career included a combination of investment banking roles and ten years M&A experience in the software sector

Two-year transformation period

Five divestments of non-core businesses to focus on marketing communications technology.

Chris Pilling appointed as Non-Executive Director

Chris joined in August 2015 as part of a successful career as a serial entrepreneur. He also acts as a chairman, Non-Executive Director and strategic advisor for a range of fast-growing technology businesses.

Product launched to mid market and Enterprise

1,500 clients including NICE.

Mark Fautley appointed Chief Financial Officer

Mark previously worked for, or on behalf of, a number of FTSE 100 and AIM businesses, including three years in a senior finance role for a $2.5 billion revenue joint venture of Rolls-Royce plc.

Christopher Satterthwaite appointed Chairman

Christopher was previously chief executive of Chime, where he oversaw growth in operating income from £54m in 2003 to £246m in 2016.

Acquisition of ResponseSource

Acquired ResponseSource to add depth and breadth to its media and influencer network.

Acquisition of Pulsar

Acquired Pulsar to accelerate its social media and audience intelligence capability.

Group surpasses 3,500 clients

Clients include NBC, Ogilvy, HSBC, Edelman, Investec and Paramount.

Organic ARR growth accelerated to 21% in 2020

New client wins include Amazon, Saatchi & Saatchi, UniCredit, and Publicis.

Sarah Vawda appointed as Non-Executive Director

Sarah is a highly experienced director, with expertise across corporate strategy, M&A, finance, corporate governance and development. More recently, Sarah has pursued a portfolio career advising large listed and PE backed companies on their strategic, transformation and M&A agenda, as well as acting as a Non-Executive Director to several companies.

Acquisition of Isentia in September 2021

Acquired Isentia, adding 2,400 clients - bringing the Group to over 6,000 clients - and 850 employees.

Strategic partnerships signed with Hootsuite & NewsGuard

Strengthening social media management and misinformation/ disinformation respectively.

97% revenue growth for the full year 2022

Benefitting from the full year of Isentia's APAC revenue along with the organic growth in EMEA and NA.

Global marcomms platform rolled out across APAC

Pulsar Group introduces global omnichannel audience intelligence to the APAC region.

Access Intelligence plc rebrands as Pulsar Group plc

Strategic rebrand signposts the Group as the audience intelligence partner of choice for the world's most relevant brands.

Max Royde appointed as Non-Executive Director

Max is Managing Partner and CEO of Kestrel Partners LLP, co-founded in 2009. He has been advising

and investing in quoted and unquoted UK smaller companies since 1998 and prior to Kestrel was a managing director of KBC Peel Hunt.

New Products Launched

Lumina, Narratives AI, CLEAR, and Crisis Oracle all released in 2025 or early 2026.

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Pulsar Group Product Innovation: Building the Decision Infrastructure for the Next Era of Communications

In a year where artificial intelligence has shifted from experimental capability to essential infrastructure, Pulsar Group plc has further strengthened its product portfolio with innovations across PR, communications, marketing, and regulatory intelligence.

Ыe industry is undergoing a deep, structural change: moving beyond volume-led monitoring and retrospective reporting toward systems that can interpret complexity, anticipate outcomes, and guide decision-making in real time. Pulsar Group's product strategy is deliberately focused on enabling this transition.

identify emerging influence, uncover perspectives different stakeholders might be developing on an issue, and detect early signals where stories may turn into reputational risk. Ыe result is a shift from passive monitoring to proactive, informed judgement.

The Lumina Era: Intelligence by Design

At the centre of this strategy is Lumina, Pulsar Group's purpose-built AI suite for PR and communications professionals. Engineered specifically to support the professional workflows of communicators, Lumina addresses the nuance, accountability, and speed required in modern communications.

Narratives AI allows users to query and explore billions of posts and articles instantly, revealing how narratives, opinions and beliefs emerge organically across platforms and communities.

During the year, Narratives AI was significantly enhanced. Platform coverage was expanded to include Bluesky, adding greater balance and reducing platform bias. Geographic filtering now enables users to see where narratives are taking hold. In parallel, LLM-inferred insights were added to enrich each narrative with context, drivers, key audiences, influential voices, and predicted trajectories. Together, these capabilities transform narratives from descriptive signals into actionable, forward-looking insight.

Pulsar CLEAR: Agentic AI for Ad Compliance

Pulsar Group also entered the regulatory technology market with the launch of CLEAR, an Agentic AI

ad compliance system designed to turn advertising compliance into a strategic enabler of creative teams. CLEAR is built on a novel hybrid architecture of specialised agents, delivering traceable, auditable assessments across text, video, image, and audio.

agentic AI products designed to operate alongside professional teams.

Pulsar Crisis Oracle: Predictive Reputation Risk

Pulsar Group also unveiled Crisis Oracle, an agentic AI system designed to predict and escalate emerging brand risk before it becomes a crisis. Moving beyond keyword monitoring, Crisis Oracle analyses narrative momentum - combining size, velocity, and visibility

- to anticipate how negative narratives may emerge, evolve and spread.

As the first of Pulsar's Oracle class of TeamMates, Crisis Oracle brings foresight directly into PR and communications workflows, enabling earlier, more confident intervention.

Anchoring the Future

Across Lumina, Narratives AI, CLEAR, and Crisis Oracle, Pulsar Group is building a coherent, actionable

Its first module, Stories & Perspectives, marks a step-change in media intelligence. Rather than presenting disconnected news coverage, Lumina clusters articles into coherent Stories, and maps the Perspectives different outlets develop for each Story. Ыis enables teams to understand how narratives form and evolve,

Narratives AI: Understanding Public Opinion at Scale

In 2025, we launched Narratives AI, the world's first search engine for public opinion. Replacing complex Boolean logic with an intuitive search experience,

By integrating directly into creative workflows and generating comprehensive advertising compliance assessments in minutes rather than weeks, CLEAR enables proactive risk management while reducing friction between creative, legal, and governance teams. CLEAR is the Group's first TeamMate, a new class of

decision infrastructure for a world defined by information complexity, regulatory scrutiny, and reputational risk. By combining agentic AI, narrative analysis, and explainable systems, Pulsar Group supports earlier, more informed judgement in complex communications and risk environments.

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Global scale

Pulsar Group has over 700 employees serving over 5,000 clients in 10 major markets around the world. While many of these customers originally accessed the Group's platforms through one of its acquisitions since 2018, they now benefit from the unified operations and a combined technical framework that is at the heart of Pulsar Group innovation and development.

Shared values and a customer-centric approach also means that the Group's clients have the highest standard of support wherever they are, from New York to New Zealand.

Ыe belief that audience intelligence is the strategic future of the marketing, PR and communications markets unites all aspects of the Group, across all markets and regions.

EMEA

EMEA remains the Group's stable foundation, with solid growth and market awareness achieved year on year. While the market is not as mature as North America, its pace of change is much greater, which is why a strong

performance here is vital to support the Group's global operations.

North America

North America is the most mature market but it has a large number of competitors and products that have failed to keep the pace of innovation that drives all other regions. Ыere is a significant opportunity for the Group

in North America, particularly in the public sector and tech brands, both of which are often already literate in the benefits of audience intelligence.

APAC

APAC is now the Group's largest market and delivered a significant turnaround in ARR performance in 2023 with further ARR growth in 2024 and 2025. It has

a huge footprint across major global enterprises and the highest levels of Government, and has proven itself perfectly positioned for the Group's land and expand strategy as more of the global product set is introduced in the region.

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Investing in people to thrive

Investing in our People, Enhancing our Corporate Social Responsibility and Focusing on Team Building Initiatives.

Executive Summary

Ыroughout 2025, the company's global offices demonstrated a comprehensive commitment to investing time and energy in creating and enhancing the place in which we work. Externally, teams engaged in a range of meaningful activities from humanitarian aid to health advocacy for underprivileged communities. Internally, the company invested heavily in strengthening employee bonds through immersive retreats, skills training, and celebratory gatherings.

Ыis report captures just a few of those initiatives and activities undertaken by teams across the world, from the UK through to Indonesia, Malaysia, the Philippines, Singapore, Ыailand, Vietnam and Australia, highlighting how these initiatives have cultivated an unstoppable company spirit and delivered tangible social impact.

Community Engagement and Humanitarian Aid A major pillar of the 2025 strategy was direct engagement with local communities to enhance our CSR outputs. Teams utilized both corporate resources and employee volunteerism to support local communities.

In the UK, our team's commitment to social responsibility was brought to life using the Volunteer Leave, where staff are entitled to paid time off to support a good cause. Our employees used the

time off to support a wide spectrum of vital causes, demonstrating the diverse passions that drive

our workforce. From physical challenges like the Construction Cup for Unseen UK and a charity hike up Snowdon to raise money for the Butterfly AVM

Charity, to community staples like local school support and assisting at charity shops during the busy festive period, our team showed up where it mattered most. We supported the arts through theatre scenery installation, promoted youth wellness via local football charities, and contributed to life-saving efforts through blood donations and the Annual Charity Golf Day for Child Bereavement UK. Ыis collective effort reflects our core belief that small individual actions contribute to a significant, positive community impact, and we're very proud of this.

In Malaysia, the team executed a significant CSR initiative in March 2025 by partnering with Persatuan Wanita Berdaya Lembah Subang (PWBLS). One department elected to redirect their designated team engagement funds to support the 'Pasar Kasih'

charity drive. Ыis employee-driven financial sacrifice, supplemented by a corporate donation, successfully provided essential food supplies to 100 families in underprivileged communities.

Furthermore, the Malaysian team supported "quiet, personal initiatives" led by staff members. In July 2025, the office rallied behind an employee-led distribution drive targeting remote communities in East Malaysia.

Ыe team contributed essential hygiene and comfort items, such as toothbrushes and socks, for children in need. Although this was a low-profile effort, the

company viewed it as an honor to support the personal philanthropic journeys of its staff.

In Singapore, the team adopted an immersive approach to CSR through a partnership with Project Dignity Pte Ltd. Ыe initiative, titled "Learn with Lunch & Outreach," was designed to be educational as well as charitable. Employees attended a briefing on how the social enterprise trains and employs individuals with disabilities. Ыe session included a basic sign language

course, fostering greater inclusivity, followed by a team lunch prepared by the program's beneficiaries. Ыe day culminated with the team breaking into small groups to pack and deliver bento meals to nearby residents, allowing staff to witness the social impact of their efforts firsthand.

Health Advocacy and Medical Support

Ыe Philippines and Vietnam teams focused heavily on health and wellness, addressing critical medical issues through education and fundraising.

Ыe Philippines Broadcast CSR team implemented a monthly thematic structure to their campaigns. In May 2025, they launched a Cervical Cancer Awareness campaign. Ыe initiative focused on educating staff about the nuances of the Human Papillomavirus (HPV), clarifying that while both genders are at risk

for HPV, women face specific risks regarding cervical cancer. Ыe campaign emphasized prevention through screening, vaccination, and healthy lifestyle choices.

Later in the year, for National Blood Donor Month in July, the Philippines team moved from education to inspiration by sharing personal stories within the company. Ыey highlighted the stories of dedicated

donors or people who received life-saving transfusions. Ыese narratives served as powerful reminders of the lasting impact of blood donation.

In Vietnam, the team channeled their energy into the "Run for the Heart" charity race in November 2025. Organized in collaboration with Gamuda Land and the Vietnam Heart Foundation, the event raised

funds specifically for heart surgeries for underprivileged children.

Ыis participation underscored the team's commitment to providing life-saving healthcare access to those who cannot afford it.

Strengthening Internal Culture and Connections Focusing internally on where improvements can be made to improve and enhance employee experience, the company invested in events designed to break down departmental silos and reward employee dedication. For example:

Indonesia hosted two major events. In March 2025 the team held a heartfelt Iftar gathering during the Muslim festival of Ramadan. Ыis shared moment strengthened bonds between regional management and local staff, emphasizing values of gratitude and togetherness.

Later, in November, the team embarked on a company trip to Bandung. Ыe itinerary was dedicated to exploring local culture and food, with the specific goal of shaping a stronger and united team spirit.

In the Philippines, the year began with the "Night of Unity and Excitement" Kick-off Event in January 2025. Ыe venue was transformed into a dazzling space where the air crackled with anticipation. Ыe highlight was a talent contest featuring musical numbers and dance routines, revealing hidden skills among the staff. Ыe event concluded with a crowded dance floor, symbolizing the team "breaking down silos and moving forward together.

In the UK, evening celebrations were held in Summer and Winter to bring together both hybrid and remote working colleagues, to celebrate successes and build connections. Ыe events included delicious food, networking, music and dancing - and even an Awards Party to call out successes within different departments.

Celebratory dinners also played a key role in Malaysia and Thailand. Ыe Malaysia team hosted a "Cowboy & Denim Night" at Ыe Westin in November, a themed evening dedicated to recognizing employee hard work

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Strategic report

outside the office environment. Similarly, the Ыailand team closed the year with a dinner in December

that focused on generating "positive energy" and "good vibes," ensuring the year ended on a high note of camaraderie.

Customer Success Team Volunteer: "Volunteering with Made in Hackney involved preparing healthy, nutritious meals for underprivileged children in the community.

I worked alongside other volunteers in the kitchen to prepare 600 meals for children in the community."

Commercial Team Volunteer: "Ыe charity I helped was Winchester Young Carers. We essentially took a number of "young carers" (defined as children that have to take care of their parents due to mental / physical health conditions) out paddleboarding

and sailing for a couple of days in the summer holiday. It gave them a chance to unwind and escape, and also meet other children in the same situation as themselves."

Professional Development and Skill Building Team building throughout the year was also approached through the lens of professional and personal development.

Ыe Vietnam team combined recreation with collaboration during a two-day, one-night trip to the coastal city of Vung Tau in May 2025. Ыe retreat featured team-based mini-games designed to improve collaboration in a relaxed setting.

In Malaysia, the focus was on safety and preparedness. In August and September, the office organized two sessions of Basic Occupational First Aid, CPR, and AED training.

Twenty-five employees participated, gaining hands-on experience in emergency response-a skill set valuable both inside and outside the workplace.

Meanwhile, the Philippines hosted a regional training session in October 2025. Singapore Report Production managers joined the SEA Insights team leads in Manila for NewsAPI training. Ыis session was critical for automating data collation and reducing manual effort, paving the way for sustainable team growth and streamlined workflows across the region.

Wrap Up

Ыe 2025 People Report highlights a transformative year where Pulsar Group successfully integrated corporate growth with a profound commitment to social responsibility and internal unity. By leveraging diverse initiatives - ranging from humanitarian

aid to critical health advocacy - our global teams delivered tangible social impact while cultivating an "unstoppable" company spirit. Simultaneously, the company's investment in immersive retreats,

celebratory gatherings, and professional development training has effectively broken-down departmental silos and enhanced the overall employee experience.

As we look beyond 2025, these collective efforts in community engagement and team building serve as the foundation for a resilient, inclusive, and mission-driven workforce prepared for sustainable future growth.

Pulsar Group delivers market leading audience intelligence, reputation management, and marketing and communications insight for blue chip enterprises around the world.

Results

Despite a challenging environment where marketing spend in particular has been restricted, Pulsar has successfully delivered another year of encouraging constant currency ARR growth to £64.5m. Pulsar has Annual Recurring Revenue increased by £3.9m this represents nearly double the growth achieved in FY24. Ыe ARR growth was driven by a 1% in increase in renewal rates and a major, multi-year contract win with a multinational marketing and communications company.

ARR	FY23	FY24 Change	FY24	FY25 Change	FY25
EMEA & North America (Constant Currency)	£29.1m	+£1.7m	£30.8m	+£3.4m	£34.2m
EMEA & North America (Reported)	£29.7m	+£1.4m	£31.1m	+£3.1m	£34.2m
APAC (Constant Currency)	£29.5m	+£0.3m	£29.8m	+£0.5m	£30.3m
APAC (Reported*)	£31.6m	-£1.0m	£30.6m	-£0.3m	£30.3m
Group (Constant Currency)	£58.6m	+£2.0m	£60.6m	+£3.9m	£64.5m
Group (Reported)	£61.3m	+£0.4m	£61.7m	+£2.8m	£64.5m

EMEA & NA continued to be the primary engine of growth, with ARR growing to £34.2m. Ыis represents an increase of £3.4m, doubling the £1.7m increase seen in FY24. We secured a significant multi-year partnership with a global marketing leader during

the year with service delivery beginning ahead of our December announcement, ensuring that €2.1m in ARR was already contributing to our FY25 performance. As global enterprises standardise on the Pulsar platform for strategic intelligence, this region remains the Group's strongest performing region.

Building on the turnaround established in FY24, the APAC region saw an acceleration in growth velocity, delivering £0.5m ARR growth in FY25 compared to

£0.3m in FY24. Ыis performance reflects both the efforts of the Isentia team and strong regional demand for the Group's enhanced AI capabilities.

Revenue in the year was £61,175,000 (2024:

£61,997,000 reported, £60,100,000 constant currency). Recurring revenue comprised 96% of the total (2024: 98%), with sales teams incentivised to focus on high contribution SaaS products. Ыe Group had an adjusted loss before interest, tax, depreciation and amortisation (Adjusted EBITDA) for the year of

£10,389,000 (2024: £9,279,000).

22 Business Overview 23 Business Overview

Strategic report

Ыe Directors believe that the disclosure of Adjusted EBITDA provides additional useful information on the core operational performance of the Group and its ongoing cost base to shareholders, and review the results of the Group on an adjusted basis internally. It is an important metric as it provides clear guidance on the on going long-term cost base and profitability of the Group.

Ыe term 'adjusted' is not a defined term under IFRS and may not therefore be comparable with

similarly titled profit measurements reported by other companies. It is not intended to be a substitute for, or superior to, IFRS measurements of profit.

Adjustments are made in respect of the Group's:

• Non-recurring administrative expenses;

• Share of profit or loss of associates;

• Profit or loss on sale of associates; and

• Share-based payment charges.

  Adjusted EBITDA is designed to highlight the

  either exited during 2025 or identified pre-year-end to exit during 2026. Non-recurring salary costs for the year were £8,121,000 (2024: £6,101,000) which

  includes the year-to-date costs and redundancy costs of roles that either exited during 2025 or which were already identified before the year end to exit during 2026. Costs related to employees who had exited the business as at year end amounted to £4,168,000 Of those exiting during 2026 the costs of those identified to leave totals £3,953,000 and by the end of March 2026, costs totalling £1,663,000 had already exited the business with £2,290,000 still to exit during 2026.

  In addition to non-recurring salary costs, the Group incurred £1,354,000 (2024: £2,050,000) of duplicated technology costs as it built out key functionality across multiple platforms. Ыese duplicated costs were eliminated by Q4 2025 and are not expected to continue into 2026. Ыe Group also had other non-recurring expenses (including realised FX) of £168,000 (2024: £410,000).

  financial performance of the Group including non-recurring costs incurred. EBITDA moved from a profit in 2024 to a loss in 2025 due to the £1,110,000 increase in Adjusted EBITDA being more than offset by the £1,082,000 increase in non-recurring costs,

  £403,000 of unrealised FX losses, and the profit on sale of associate made in the prior year.

  Statutory Results

  Loss before taxation was £9,450,000 (2024:

  £6,670,000). In arriving at the loss before taxation, the Group has incurred £1,106,000 of net financial expense (2024: £566,000) and charged £8,261,000 in depreciation and amortisation (2024: £7,570,000).

  £1,654,000 of this charge related to the amortisation of intangible assets arising on acquisition (2024:

  £1,707,000). Ыe loss before taxation has increased due to the EBITDA loss in the year, a £691,000 increase in depreciation and amortisation expense, and a £540,000 increase in financial expense.

  Loss per share

  Ыe net cash inflow from financing activities for the year was £486,000 (2024: inflow of £1,421,000), reflecting the drawdown of loans, plus interest and lease liability repayments in respect of the Group's head office.

  Subsequent to the year end, on 30 April 2026, the Group put in place a new £6,000,000 bank loan and

  £2,000,000 RCF.

  Key performance indicators

  Management accounts are prepared on a monthly basis and provide performance indicators covering annual contract value, revenue, gross margins, Adjusted EBITDA, EBITDA, result before tax, result after tax, cash balances and recurring revenue.

  Recurring revenue is the proportion of Group revenue which is expected to continue in the future. Ыe key performance indicators for the year are:

  2025 2024

  £'m £'m

  performance of the Group's core business expected to continue post rationalisation and integration. It excludes non-recurring administrative expenses of

  £9,643,000 (2024: £8,561,000), a share of loss of associate of £Nil (2024: £128,000), a profit on the sale of an associate of £62,000 (2024: £1,457,000) and a share-based payments charge of £488,000 (2024:

  £580,000).

  Adjusted EBITDA also excludes unrealised FX gains

  Ыe Group delivered more than £7.0m in annualised cost savings during 2025, primarily through automation and the decommissioning of duplicate legacy technology across the Group. Overall Group headcount has reduced by 23% from 918 FTE in November 2024 to 710 FTE as at April 2026. Ыe continued focus on operating model optimisation has helped Pulsar to deliver year on year Adjusted EBITDA growth of 12%, and an improvement in Adjusted EBITDA margin from 15.0% in 2024 to 17% in 2025.

  Ыe basic loss per share was 7.83p (2024: 5.94p).

  Cash

  Cash at the year-end stood at £384,000 (2024:

  £1,001,000). Ыe Group had £6,000,000 debt at the year end (2024: £5,943,000). Ыe total decrease

  in cash and cash equivalents during the year was

  £617,000 (2024: decrease of £1,247,000). Ыe total increase in debt during the year was £57,000 (2024:

  £5,943,00).

  Annual Contract Value base Revenue

  Reported loss before taxation	(9.5)	(6.7)
  Reported loss after taxation	(9.6)	(6.6)
  Cash	0.4	1.0
  Recurring revenue	58.9	60.6

  Gross margin (%) Adjusted EBITDA EBITDA (loss)/profit

  64.5 61.7

  61.2 62.0

  69% 73%

  10.4 9.3

  (0.1) 1.5

  and losses totalling £403,000, which have been stripped out of total non-recurring administrative expenses and shown in its own line for reporting purposes in 2025.

  Non-recurring administrative expenses include costs incurred in relation to restructuring and non-core roles

  Adjusted EBITDA is £10.4m (2024: £9.3m reported,

  £8.9m), in line with the Board's expectations.

  Ыe Group's earnings before interest, tax, depreciation and amortisation (EBITDA) loss for the year was

  £83,000 (2024: profit of £1,467,000). EBITDA is

  an important metric as it provides guidance on the

  Ыe net cash inflow from operations during the year was £4,814,000 (2024: outflow of £74,000). Ыe net cash outflow from investing activities for the year was

  £5,963,000 (2024: outflow of £5,524,000), reflecting the continued investment in the Group's products.

  Ыese performance indicators are measured against both an approved budget and the previous year's actual results. Further analysis of the Group's performance is provided earlier in this Strategic Report.

  24 Business Overview 25 Business Overview

  Strategic report

  Each month the Board assesses the performance of the Group based on key performance indicators. Ыese are used in conjunction with the controls described in the corporate governance statement and relate to a wide variety of aspects of the business, including: new business and renewal sales performance; marketing, development and research activity; year to date financial performance, profitability forecasting and cash flow forecasting.

  Changes in accounting policies

  Ыere were no changes in accounting policies adopted by the Group during the year.

  Principal business risks and uncertainties Ыe developing nature of the business dictates that the Board understands the market in which it competes and the strategy that it is implementing.

  Ыe Statement of Corporate Governance notes the objectives and mechanisms of internal control. Regular Board meetings are held, where strategy is discussed and decisions taken, supplemented by more regular operational meetings held by the management team. Ыe Board regularly assesses risks and is of the belief that internal control, risk management and stewardship are integral to the proper management of the business. Further information in relation to risk management is provided on page 27 of the Strategic Report and within Note 18 to the consolidated financial statements.

  Ыe Board also assesses the appropriateness of preparing the financial statements on a going concern basis and their considerations in respect of the risks relating to going concern are outlined within the Directors' Report on page 98.

  Financial instruments

  Ыe Group's operations are subject to a variety of financial risks, including cashflow and liquidity risk. Liquidity risks are set out on page 30 of the Strategic Report and in Note 18 to the consolidated financial statements. At the year end it had a £3,000,000 overdraft facility and a £3,000,000 loan facility, both were replaced by the new £6,000,000 bank loan

  and £2,000,000 RCF entered into on 30 April 2026.

  £3,600,000 of the new bank loan amortises on a straight line basis over three years whilst the remaining

  £2,400,000 is repayable after three years. Ыe RCF is in place for three years.

  Ыe Group held £384,000 (2024: £1,001,000) of bank deposits.

  63% (2024: 64%) of the Group's revenue is invoiced in a currency other than sterling. With the acquisition of Isentia during 2021, foreign exchange risk has become a more significant consideration for the Group, albeit the Board has assessed that in most territories the value of non-sterling revenue is offset by the value of non-sterling payroll and third party supplier costs. With no significant international cash transfers around the Group anticipated at present, no hedging of currency exposure has been undertaken. At 30 November 2025 there were no open exchange contracts.

  A significant financial risk to which the Group is exposed is that of the credit worthiness of our customer base. Around 28.8% (2024: 28%) of the Group's revenue is contracted with the public sector where the directors have judged the credit risk to be minimal. Ыe remaining sales are with the private

  sector where we have experienced a small incidence of credit losses.

  We have not considered it necessary to take out credit insurance for the following reasons:

  • almost all customers are invoiced in advance;

  • most receivable balances are not of a high value;

  • no significant concentration of receivable balances are with any one customer;

  • and in many cases, we have the ability to switch off the service the moment a debt becomes overdue.

  Ыe Group holds a number of deposits with well-known banks. In recent years we have become increasingly aware that even financial institutions such as banks are not immune to financial risk. Ыis was demonstrated in March 2023 when Silicon Valley Bank (SVB), one of the Group's bankers, failed after a bank run. Pulsar Group holds cash with a number of separate banks globally to mitigate risk and is satisfied with their credit worthiness at this time.

  Information about the use of financial instruments by the Group is given in Note 17 to the financial statements.

  Risk management

  Risk management process

  Ыe success of the Group depends on the proper management of risk. Effective risk management is essential to support the achievement of our strategic and operational activities.

  Ыe Group's activities expose it to a variety of strategic, operational and financial risks which are managed through the governance structure, by Group and subsidiary management teams as part of their day-to-day responsibilities.

  Ыe Board has overall responsibility for the risk management framework and the Group's overall risk management policy, which focuses on those areas of exposure most relevant to its operations. Detailed below are the principal risks and uncertainties that the Board believe could have a severe impact on the Group's business and the corresponding action the Group, led by the Board, is taking in order to manage them.

  26 Business Overview 27 Business Overview

  Risk type and description Mitigation Monitoring / Governance oversight

  Economic or political disruption risk

  Risk type and description Mitigation Monitoring / Governance oversight

  Information security risk

  Ыe wide ranging impact of COVID-19 has demonstrated how a major health pandemic can cause significant disruption

  to global demand and growth. Furthermore, the ongoing war in Ukraine and resulting sanctions introduced by the UK, EU and USA against Russia, escalating tension in the Middle East and political changes in the USA highlight how changes in the global political environment can rapidly affect demand and business operations within certain

  territories and regions.

  Ыe potential impacts of economic or political disruption are likely to relate to demand for our products and services, our ability to maintain operations or on the cost of our delivery of services.

  Competitive risk

  All of our brands are active in growing markets and face both local and global competition for customers and employees.

  Ыe potential impact of not appropriately understanding and managing competitive risk is that revenue and profitability may decline over a sustained period of time if competitors are able to offer better products and a better customer experience.

  Pulsar Group has operations in four continents and 10 markets around the world. Management monitors the ongoing economic and political situation in the territories in which it operates to assess the level of risk in respect of economic or political factors.

  Ыe diversity of the Group from both a geographic and technological standpoint also helps to mitigate against potential economic or political disruption as demand is not centred in any single location

  and operations can be delivered from a number of different locations.

  As a Group we need to ensure that we are able to attract the best talent across our business. We need to develop market leading products and be able to sell the additional value of our products compared to those of our competitors.

  As an agile company focussed on creating long-term shareholder value, we need to manage our product investments with care and we tackle these risks as follows:

• We encourage investment as needed to maintain our market leading status through product research and development;

• We prioritise to stay relevant for newer generations and new media models;

• We are growing our sales and marketing teams across the Group in a controlled manner;

• We make time and funds available for staff training;

• We incentivise through balanced sales commission schemes; and

• We monitor individual sales person performance, taking action where necessary to ensure that commercial staff have a full understanding of the unique benefits and attributes of our products compared to those of competitors.

  Ыe Chief Executive Officer and Chief Financial Officer provide the Board with regular updates on the Group's global operations and local developments in key territories.

  Ыe Chief Executive provides the Board with regular updates on market and competitor activity.

  We seek to protect the Group and its stakeholders from the impacts that could occur due to threats and vulnerabilities associated with the operation and use of information systems and the environments in which those systems operate.

  Ыe potential impacts of not appropriately managing information security risk include but are not limited to disruption to customer facing products and/or internal systems, data breaches, fines from relevant authorities and lost revenue.

  Ыe Group has clear policies and procedures in place to:

• Direct the design, implementation and management of a coherent and consistent ISMS, which ensures that information assets are adequately identified, always recorded and afforded suitable protection;

• Ensure the confidentiality, integrity and availability of Pulsar Group's information assets and supporting assets (including information systems);

• Ensure that all vulnerabilities, threats and risks to information assets and supporting assets are formally identified, understood, assessed and controlled in accordance with the Group's documented Risk Assessment Methodology;

• Ensure that Pulsar Group's employees, contractors and third-party users comply with its Information Security Policy, and all other ISMS documentation, through the provision of effective information security training, awareness and ongoing monitoring activities; and

• Ensure that Pulsar Group can maintain full compliance with all applicable legislation, regulations and contractual requirements, and any supporting management system certifications (e.g. ISO/IEC 27001:2022).

  Pulsar Group has established an Information Security Management System (ISMS) aligned with the international standard ISO/IEC 27001:2022.

  Ыis framework underpins all information security activities across the organisation, and Pulsar Group maintains independent external certification against this standard. In addition, Pulsar Group is certified to Cyber Essentials Plus, demonstrating a verified baseline of technical controls to protect against common cyber threats.

  A monthly ISMS review meeting is held which is attended by one or more of the executive directors. Key feedback from the monthly ISMS review meeting is provided to the Board.

  28 Business Overview 29 Business Overview

  Risk type and description Mitigation Monitoring / Governance oversight

  Treasury, FX and liquidity risk

  Risk type and description Mitigation Monitoring / Governance oversight

  Key personnel risk (Continued)

  Ыe Group operates in 10 markets around the world with a number of local currency requirements in different territories. As a Group we support the cash requirements of operations in each territory, all of which

  have individual working capital requirements during any month.

  An important component of cash flow performance is the Group's ability to collect cash from its customers. As such, credit control forms a key element of overall treasury and liquidity risk.

  In addition, as an acquisitive business which continues to invest in developing market-leading products and services, there is

  a fundamental need to project future cash requirements.

  Ыe potential impact of not appropriately managing treasury and liquidity risk includes local operations having insufficient cash in appropriate currencies to pay employees

  or suppliers.

  Changes in foreign exchange rates could lead to realised losses when paying suppliers or receiving money from customers

  Key personnel risk

  Ыis is a people business. Our technical staff create the product and our sales staff sell it, supported by our marketing staff. In 2025: 42% (2024: 47%) of our outflows were

  on people.

  Management carefully monitors cash performance by territory and by currency on a weekly basis.

  Performance compared to Budget is reported to the Board on a monthly basis.

  To ensure that the Group carefully manages its cash resources, it maintains a number of initiatives:

• Paying sales commissions where appropriate but only once cash is received for larger sales;

• Monitoring detailed ageing analysis of debtors from each territory on an ongoing basis; and

• Reforecasting cash requirements and taking appropriate action where required, e.g. moving funds into appropriate currencies or evaluating the requirement for bank debt or additional equity funding.

  Our sales are split 29%:71% (2024: 28%:72%) between public and private sector organisations. Whilst recognising that circumstances change, we are of the opinion that the public sector will pay its debts providing the purchasing rules have been followed.

  Ыe private sector however remains a higher risk and we remain diligent about our approach to these sales and endeavour to only deal with companies which are demonstrably creditworthy.

  At the end of 2025 we had £3,000,000 bank borrowings (2024: £2,943,000) and £3,000,000 other loans (2024: £3,000,000). Subsequent to the year end the bank overdraft and other loans have been replaced by a new £6,000,000 loan facility and

  £2,000,000 RCF

  We address personnel risk in a number of ways:

• We take care to take references when recruiting;

• Managers monitor performance individually whatever the role in the organisation;

• We offer training of specific skills where appropriate;

  Ыe Group ensures sufficient liquidity is available to meet

  foreseeable needs and to invest cash assets safely and profitably and the details are regularly monitored by the Chief Financial Officer.

  Ыe Board regularly reviews succession planning and receives updates on senior talent management programmes.

  In a competitive market we recognise good people can be poached or just lose their way. Ыere is nothing that can beat a motivated, educated and focused team.

  Capital risk management

  Ыe Group's objectives when managing capital are to safeguard the Group's ability to continue as a going concern providing long-term returns for shareholders and security for other stakeholders whilst maintaining optimal

  capital structure to allow for future acquisition and growth.

• We encourage flat management structures, open plan offices and easy accessibility up and down the organisation;

• We pay competitive market prices whilst recognising regional differences;

• We have an approved option scheme for senior employees; and

• A number of key personnel are significant shareholders in their own right.

  In order to manage the overall objective above, the Group gives consideration to the following:

• Ыe Board views equity firstly as the key source of funding for acquisitions and secondly as an important incentivisation tool for management. Ыese are the key justifications for the Group's AIM quotation.

• In relation to acquisitions, the appropriate funding structure will be a blend of our own available cash, gearing and equity. Ыe structure for each transaction will take into account our intention for an immediate enhancement in earnings per share.

• Ыe Board is also sensitive to the fact that there may be times when capital is in short supply justifying fundraising beyond our immediate needs. With a buy and build strategy new acquisition opportunities must be responded to as they arise.

• As an incentive for management, we offer equity based payments in line with market prices at the time of grant, aligning the long-term interests of shareholders and key executives.

• Ыe total capital managed by the Group at the year-end was 138,524,386 (2024: 130,524,386)

  ordinary shares of 5p (2024: 5p) each. Further information on share capital is provided within Note 20 to the consolidated financial statements. Ыe Group is not subject to any externally imposed capital requirements.

  Ыe Group reviews the budgets and forecasts on a regular basis to ensure there is sufficient capital to meet the needs of the Group.

  30 Business Overview 31 Business Overview

  Risk type and description Mitigation Monitoring / Governance oversight

  AI Risk

  Strategic report

  As generative AI and automated systems continue to evolve, Pulsar Group remains proactive in safeguarding our market position and ensuring our product suite provides value that transcends commoditised AI outputs.

  We view AI as a powerful utility rather than a replacement for our core value proposition.

  Our mitigation strategy centres on the integration of proprietary data-which serves as a "moat" against generic models-and the continuous refinement

  of our specialised workflows. By embedding AI capabilities directly into our existing infrastructure, we transform potential disruption into a feature set that enhances user productivity.

  Beyond technical integration, our primary defence against AI displacement is our deep understanding of the human-in-the-loop complex problem-solving that our customers require. While AI can automate tasks, it cannot replicate the institutional knowledge, compliance rigor, and strategic intuition built into our platform

  Ыe board must ensure that the product's value isn't being eroded by free AI tools.

  Ensure our AI doesn't provide hallucinations that damage our brand.

  Stakeholder engagement

  Section 172(1) statement

  Ыe Group's long-term success depends on our ability to create value for our stakeholders. Our engagement activities, set out on pages 33 to 36, enable us to understand what matters most to our stakeholders and how key decisions will affect them.

  Ыe Board considers the matters set out in Section 172(1) of the Companies Act 2006 when making decisions which we consider promoted the success of the Company for the benefit of its stakeholders. Ыis report serves as our Section 172 statement and sets out how the Directors, both individually and

  collectively, have had regard to the factors as set out in the Companies Act 2006 when undertaking their duties during the year.

  We consider our key stakeholders to be our employees, customers and clients, investors, suppliers and the communities in which the business operates. Ongoing engagement with all stakeholder groups is important in

  strategic decision-making. Ыe Board recognises the criticality of stakeholder engagement in developing and delivering our strategy, culture, long-term success, and keeping pace with market initiatives and technological changes.

  Engaging with stakeholders enables the Group to understand their needs more effectively which in turn helps the Group make more informed business decisions. Ыe Directors are conscious that their decisions and actions impact stakeholders, and stakeholder feedback was considered in the Board's

  deliberations and decision-making. Below are details of how the Board engaged with our five key stakeholder groups during the year. Ыat engagement may be shaped by the Board and is taken into account by the Directors in the performance of their duties.

  Ыroughout the year, management provided the Board with presentations and information, including reports and Board papers. Ыe Board discussed and deliberated on the impact on stakeholders when making decisions.

  Stakeholder group Why we engage How we engage Outcomes of engagement

  Investors

  Our shareholders play an important role in the success and growth of the Group.

  Ыey provide the capital we need to use in the business. Pulsar Group is an AIM-listed company, and therefore we have certain obligations in providing information to our investors.

• Trust from our shareholders is key to delivering our strategy and long-term success.

• We endeavour to provide fair, balanced and meaningful information to both existing and potential shareholders throughout the year, to understand their needs and expectations, and to ensure that the Group's strategy,

  •Ыe Board has maintained regular, open, and robust communications with the Company's shareholder base and the market during the year in order to ensure that investors remain informed and are consulted on the Group's financial performance and strategic plans.

  •Ыe Chief Executive Officer and Chief Financial Officer meet with representatives of most major institutional shareholders at least twice a year. Following the release of our year end results in April 2025 and our interim results in July, an extensive engagement programme was undertaken with investors to discuss their views.

• Engagement with our investors enables them to gain improved knowledge and understanding of the Group and its operations and activities.

  •Our investor engagement activity and feedback

  are discussed regularly at Board meetings and factored into decision-making by the Group

  32 Business Overview 33 Business Overview

  Stakeholder group Why we engage How we engage Outcomes of engagement

  Stakeholder group Why we engage How we engage Outcomes of engagement

  What matters to them:

  • Financial performance and business sustainability

  • High standards of governance

    •Ethical behaviour and a responsible business

  • Awareness of long-term strategy and direction

  • Alignment of strategy with the interests of investors

    Customers

  • Our customers are key to the long-term success of our business and without them we would not have a business.

  • What matters to them:

  • Product range, price and quality

  • Timely and informative end-to-end service

  • Convenience and accessibility

  • Ease of access to information

  • Technical expertise

  • Data security

    business model and financial performance are clearly understood.

• Understanding the needs of our customers is fundamental to our long-term success.

• We focus on understanding how our products and services can meet their needs and are delivered

  in a straightforward and transparent way.

• We target our innovation on key areas of demand to ensure we remain competitive.

•Feedback from investor meetings was shared with the Board to ensure the Directors understand their unique circumstances, expectations and motivations.

•Shareholders are invited to submit questions to the Board at the Annual General Meeting and Directors attend the AGM and make themselves available

to answer questions from shareholders. Where shareholder voting decisions are not in line with expectations, the Board will engage with shareholders to understand the reasons for this.

•Investor information including the annual report and accounts, RNS announcements and press releases are available on the Company's website. An investor relations email account is maintained and which

is constantly monitored for any communication or concerns raised by investors. Ыe Board will discuss any concerns that are raised.

•Pulsar Group listens to its customers and takes onboard their feedback to ensure that the platforms evolve, and technology used continues to meet the demands of its customers.

•Ыe Group's brand has continued to evolve in order to keep pace with the Group's expansion, growth and global reach.

•Ыe Board receives regular updates from management regarding new client wins, existing customer relationships and the customer pipeline.

•When negotiating customer contracts, where commercially appropriate, the Group considers customers' views and opinions, and senior managers regularly engage with customers to understand their challenges and growth priorities.

•Ыe Group recognises the importance of system security for our customers and has retained its ISO/ IEC 27001 and ISO/IEC 9001 accreditations to ensure that its process and procedures are of an appropriate quality standard and that its information security procedures are appropriate. Ыis is further supported by additional certification in Cyber Essentials and GDPR compliance.

•All customers can access relevant financial performance information on the Company's website.

Board.

•Transparency of Group information is available on the Company's website

•Based on engagement with investors during the year, the Group completed an operational restructure to deliver profitable growth and put in place additional financing to provide extra liquidity.

•Effective engagement is key to attracting and retaining customer relationships.

•We aim to invest in the technology, services and teams to enhance our relationships and create long-term value for

both the Group and our customers.

•Customers are the key consideration when forming long-term strategy for the Group and their interests are always considered before any key decisions are made.

Employees

A talented and engaged workforce committed to upholding our values are key to our success.

What matters to them:

• Training and career development

• Working conditions

• Diversity and Inclusion

• Fair pay and employee benefits

• Open and transparent communication

• Responsible use of personal data

  Community and Environment

  We strongly believe in reducing the impact of our actions on the environment to ensure the long-term sustainable future of the Group and in supporting our employees with their charitable endeavours.

  What matters to them:

• Employment opportunities for the local workforce

• Reducing environmental impacts

• Supporting local communities

• Charitable contributions

• Engagement across the Group provides the platform to promote the Group's corporate culture, ethical values, behaviours and expectations and to drive our long-term success.

• Staff engagement helps us attract, develop and retain

  a high-calibre talent pool and ensures our employees feel appreciated, are able to provide feedback, and can participate in the

  development of the business.

• We invest in our people to ensure every individual has the support they need to develop their career at Pulsar Group.

• Ыis includes formal training and tailored personal development plans with job-related mentoring.

  We strive to be a good corporate citizen and operate in a responsible way, showing consideration for those around us and making a positive impact on the society in which we operate.

  •Employee annual performance reviews are conducted and managers are encouraged to hold regular, informal one-to-one sessions with each of their direct reports to discuss and identify any individual training and development needs.

  •Ыe Group operates a range of localised training programmes designed to equip employees with the skills they need to perform their job roles, meet strategic targets and develop their careers with us.

  •Employees have access to employee assistance programmes in the UK and ANZ, which offers wellbeing resources and telephone counselling. Employees also have access to an anonymous whistleblowing service.

  •Employees are provided with regular updates on business activities.

  •Ыe Group is committed to making a positive impact in the communities in which it operates.

  •Ыe Group has partnered with charities to provide pro bono marketing support.

  •Employees are encouraged to raise money for charities and their endeavours may be supported either by the Group or personally by individual Directors.

  •Ыe Group's policy with regards to the environment is to ensure that the actual and potential environmental impact of its activities are managed at all times.

  •Ыe Group complies with legal requirements regarding the environment in all areas where it carries out business.

  •Ыe executive Directors provide regular updates to the Board on the Group's ESG strategy.

  •Engagement ensures that employees remain informed and are therefore more engaged.

  •Ыe Group provides all the necessary support required for employees to work flexibly.

  •Ыe Group has an integrated training programme for all new starters to establish an appropriate and consistent approach to the delivery of the proposition with a focus on culture.

  •Many employees are now working flexibly following changes introduced in response to the pandemic in 2020, which has had

  a positive impact on the environment through reduced emissions. Ыe Group's office space is designed to be highly efficient with low energy usage.

  •Ыe Group has established a Green Committee in

  the UK which, along with Isentia's Corporate Social Responsibility Committee, have responsibility for implementing steps to improve sustainability.

  •Further information regarding the Group's ESG strategy can be found in the Environmental, social and governance report on pages 61 to 75.

  34 Business Overview 35 Business Overview

  Stakeholder group Why we engage How we engage Outcomes of engagement

  Suppliers

  It is important to us that our suppliers have strong compliance, quality, service, and an ethos of innovation. What matters to them:

• Engagement and management to prevent modern slavery

• Fair trading and payment terms

• Collaboration

• Long-term partnerships

  We need to maintain reliable relationships with suppliers for mutual benefit and

  to ensure they meet our standards which range from quality and value for money through to business ethics.

  •Ыe Group recognises the importance of our existing supplier relationships but at the same time is committed to new suppliers to enhance our business and to provide resilience.

  •Ыe Group considers suppliers to be important partners in its business activities and our Supplier Code of Conduct is designed to develop mutually beneficial trusting relationships with our suppliers based on the concepts of fairness, coexistence, transparency and

  co-prosperity.

  •Ыe quality of the product, software and services we deliver to our customers is heavily influenced by the careful management of key supplier relationships, including those relating to product hosting and the supplier of key data feeds used in the products.

  •Pulsar Group conducts comprehensive supplier assessments prior to on-boarding and during their tenure. Pulsar Group also engages in active dialogue with suppliers that support its goal to increase innovation on products and digital services.

• Engagement allows us to build long term, mutually supportive relationships with our suppliers and supports the Group's overarching responsibility for ensuring that our entire supply chain upholds appropriate standards in respect to human rights, labour and the environment.

• During the year, the Board approved the Group's Modern Slavery Statement, a copy of which is available to view on the Company's website.

  Principal decisions made during the year

• 2026 Budget approval (December)

• Trading update approval (January)

• Continued strategic oversight and drive for operational harmonisation with strategy, including adoption of an AI first approach across all departments to aid agility and ingenuity while capitalising on new markets (April)

• Approval of Modern Slavery Statement (June)

• Approval of fundamental realignment of Group operating model

By order of the Board

J Arnold Director

Approved by the directors on 5 May 2026

36 Business Overview

Environmental, Social and Corporate Governance

Annual Report 2025

38 39

38 Environmental, Social and Corporate Governance 39 Environmental, Social and Corporate Governance

Directors and advisers

The Board

Directors:

Executive directors:

J Arnold (Chief Executive Officer)

M Fautley (Chief Financial Officer)

Non-Executive Directors: C Satterthwaite (Chairman) C Pilling

M Royde S Vawda

Company secretary:

Beyond Governance Limited

Registered office: Northburgh House 10 Northburgh Street London

EC1V 0AT

Company registration number:

04799195

Nominated adviser and broker: Cavendish Capital Markets Limited One Bartholomew Close

London EC1A 7BL

Registrars:

Neville Registrars Limited Neville House

Steelpark Road Halesowen B62 8HD

Bankers:

Bank of Scotland Plc 300 Lawnmarket Edinburgh

EH1 2PH

HSBC Innovation Banking Alphabeta

14-18 Finsbury Square London

EC2A 1BR

Commonwealth Bank of Australia Level 8, CBP South

11 Harbour Street Sydney

NSW 2000

Legal advisers: Fieldfisher LLP Riverbank House 2 Swan Lane London

EC4R 3TT

Auditor:

BDO LLP

55 Baker Street London

W1U 7EU

Joanna Arnold

Chief Executive Officer

Joanna joined the Group as COO in 2011 and became CEO in 2014, leading the company to become the market leader in audience intelligence and a global marcomms innovator. Under her leadership, Pulsar has accelerated the shift from omnichannel monitoring and insights to AI-enabled decision intelligence, embedding advanced language models and advanced data assets into products and workflows across its AI suite for communications professionals.

Today, the business is known for its commitment to using technology responsibly to transform relationships between business, media, government and the

public. Her vision is a world of open and authentic communication, where organisations can act with confidence despite information overload, synthetic content and misinformation. Pulsar now serves over 5,000 customers, with more than 30,000 journalists, politicians and influencers using the software. Ыe Group continues to invest in information integrity capabilities, including explainable insight generation, provenance and credibility signals, and governance frameworks designed for high-stakes communications use cases.

Before Pulsar Group, Joanna's career included a combination of investment roles and ten years' M&A experience in the software sector.

Christopher Satterthwaite Non-Executive Chairman

Christopher spent 15 years as Chief Executive of Chime Communications PLC before it was taken private by Providence Equity for £374 million in 2015. He is currently chair of Zinc Media also listed on AIM, Chair of Sine Digital a private digital marketing agency and Chair of the National Youth Orchestra.

Committee Memberships: Remuneration Committee and Audit Committee (permitted by QCA Code).

External appointments: Chair NYO, Trustee Queen Elizabeth Scholarship Trust Limited; Chair Sine Digital: Chair Zinc Media Group plc.

40 Environmental, Social and Corporate Governance 41 Environmental, Social and Corporate Governance

The Board

Mark Fautley

Chief Financial Officer

Sarah Vawda

Senior Independent Director

Chris Pilling

Non-Executive Director

Max Royde

Non-Executive Director

Mark was appointed CFO in August 2017, having joined the Group through acquisition in 2015. He has managed local and international finance teams in the Technology and Media sectors for more than 20

years and has significant experience within SaaS businesses operating in the global marketing and communications industries.

Mark has been employed by, or delivered consulting engagements for, a number of FTSE 100 and AIM businesses and has worked on the ground in 19 countries across Europe, Latin America and the Asia Pacific region. He has experience in global M&A, fundraising and other corporate finance activities.

Mark qualified as a Chartered Accountant in 2006 and is a Fellow of the Institute of Chartered Accountants in England and Wales (FCA).

Sarah joined the Group as Non-Executive Director in March 2021 and was appointed Senior Independent Director in April 2023.

Sarah is a highly experienced executive and Non-Executive Director, with expertise across corporate strategy, M&A, finance, corporate governance and corporate development. Sarah qualified as a chartered accountant at PwC before moving into senior M&A and corporate development roles within both private and public global organisations across multiple industries, including Powergen Plc, Corus Group

plc, Christian Salvesen plc, Provimi SA and Johnson Matthey plc. More recently, Sarah has pursued a portfolio career advising large listed and PE backed companies on their strategic, transformation and M&A agenda, as well as acting as a Non-Executive Director to several companies.

Committee Memberships: Audit Committee (Chair)

External appointments: Refugee Support Group (Chair) and Noveltech Feeds (Non-Executive Director, Nominaton Committee Chair and Remuneration Committee Chair).

Chris Pilling joined the Group as Non-Executive Director in August 2015.

Chris is a serial entrepreneur who possesses a wealth of experience in the development of global software and data businesses.

He founded several media, data and technology businesses including Complinet which specialised in the provision of governance risk and compliance

solutions for the financial services industry. After the sale of Complinet to Ыomson Reuters, Chris served as the SVP of its Compliance and Regulatory Risk division.

He acts as a Chairman, Non-Executive Director and strategic advisor for a range of fast-growing technology businesses.

Committee Memberships: Remuneration Committee (Chair)

External appointment: Elliptic (Chairman), Fixr (Chairman), Xapien (Chairman) and ComplyAdvantage (Director).

Max Royde joined Pulsar Group as Non-Executive Director in August 2024.

Max is Managing Partner and CEO of Kestrel Partners LLP, co-founded in 2009. He has been advising

and investing in quoted and unquoted UK smaller companies since 1998 and prior to Kestrel was a managing director of KBC Peel Hunt.

Max currently holds board positions for portfolio companies - Pulsar Group plc, Team Internet Group plc and holding companies within the group that owns IQGeo Group Limited (a private company) - as well as having a directorship at Findlay Park Partners LLP.

42 Environmental, Social and Corporate Governance 43 Environmental, Social and Corporate Governance

Chairman's corporate governance statement

I am pleased to present the Corporate Governance Report for the year ended 30 November 2025 on behalf of the Board.

Introduction: What Corporate Governance means at Pulsar Group

Ыe Group's long-term success depends on our commitment to exceptional corporate governance standards, which underpin the confident delivery of all the information contained in this Annual Report. We view governance as the cornerstone of our conduct, decision-making, business operations,

and trust-building. Good governance gives the Board and our colleagues the opportunity to advance our achievements and act responsibly toward all

our stakeholders.

QCA Code

Ыe Company is listed on AIM and is committed to ensuring the operation of high standards of corporate governance. It has adopted Ыe Quoted Company Alliance Code ("the QCA Code") as its governance framework and has put in place the appropriate procedures and policies to comply. Ыe Company

has complied with all principles of the QCA Code throughout the year. Disclosures required by the QCA Code have been made both in this Annual Report and on our website.

Following the QCA's publication of an updated code in 2023 with effect from 1 April 2024, the Company carried out a thorough review of the new QCA Code requirements to ensure compliance. Further detail on the application of the new QCA Code can be found on page 54.

Sustainability

Ыe Board is responsible for ensuring the long-term sustainability of the Group for the benefit of all of our stakeholders and sustainability is a key theme of Board and Committee discussions. Ыe Board is conscious that the Company must play a leading role in addressing the impact of climate change and the steps the Company can take to lessen our own

environmental impact. Further detail can be found in the Environment, social and governance report

on page 61.

Stakeholders

Ыe existing mechanisms for consultation, dialogue and feedback to the Board have proved effective, ensuring the continuous flow of information between the Board, senior management and our key stakeholders throughout the year despite the challenges involved. Details of the engagement undertaken during the year can be found in our Section 172 statement on pages 33 to 36.

Board changes

Ыere were no changes to the Board and its membership this year.

Diversity and Inclusion

Ыe Board remains committed to ensuring that its composition and that of the wider workforce reflects the markets we operate in and the Company provides an environment where everyone can succeed. More detail can be found on page 66.

45 Environmental, Social and Corporate Governance

44

Environmental, Social and Corporate Governance

Chairman's corporate governance statement

Evaluation

We carry out internal performance evaluations of the Board and its committees annually. Details of the evaluations are on page 51.

Corporate governance

Directors

Non-Executive including Chair	Executive
Total 4	2
Gender
Male 3	1
Female 1	1
Nationality
British 4	2
Ethnicity
White 3	2
Other Ethnicity 1	-
Tenure
5 - 10 years 2	2
4 years 1	-
3 years -	-
2 years -	-
1 year 1	-
Less than 1 year -	-

Ыe Directors who held office during the year were as follows:

Looking forward

Ыe Board's focus during the coming year will be to deliver against the Group's strategic plan to accelerate global growth. Ыe Group's technology enables its customers to develop deep audience understanding that is fully actionable, allowing them to respond in real time to intelligence and continually learn from connections.

C Satterthwaite J Arnold

M Fautley C Pilling M Royde S Vawda

Chairman, Non-Executive Executive

Executive

Non-Executive Non-Executive

Senior Independent Director

Across all regions, the Board is focussed on improving margin and cash generation as a priority during 2026, alongside accelerated growth.

Christopher Satterthwaite Chairman

5 May 2026

Board Diversity

Diversity of skills, backgrounds and cognitive and personal strengths is a critical driver of a Board's effectiveness. We believe that having a diverse and inclusive culture led by a Board consisting of a range of skills, experiences and social and ethnic

backgrounds will enable better decision-making and ultimately improve the Company's prospects and competitive advantage over the long-term.

46 Environmental, Social and Corporate Governance 47 Environmental, Social and Corporate Governance

Corporate governance

Meeting Attendance

Christopher Satterthwaite Joanna Arnold

Mark Fautley Chris Pilling Sarah Vawda Max Royde

Board meeting attendance

12 (12)

11(12)

12 (12)

11(12)

10 (12)

11 (12)

Audit committee

attendance

6 (6)

N/A N/A N/A 6 (6)

N/A

Remuneration committee attendance

1 (1)

N/A N/A 1 (1)

N/A N/A

Roles and responsibilities

Board composition

As at 30 November 2025, the Board comprised a Non-Executive Chairman who was independent on

appointment and remains so, two Executive Directors, a Senior Independent Director, one Independent

Non-Executive Director and a Non-Independent Non-Executive Director. Ыe Board is supported by the Company Secretary and senior management.

Ыe Board is satisfied that it has an effective and appropriate balance of skills and knowledge, including a range of financial, commercial and entrepreneurial experience. Ыe Board is also satisfied that it has

a suitable balance between independence and knowledge of the Group to enable it to discharge

• to monitor and assess financial performance;

• to embed a framework of controls which allow for the identification, assessment and management of risk; and

• to ensure the Group fulfils its obligations to shareholders, employees, clients and other stakeholders by promoting the long-term sustainability of the Group.

  Ыe Chairman is also responsible for ensuring that the Board takes an active and constructive part in supporting and challenging management in

  the development of our strategy and overall commercial objectives. Ыis also includes Board succession planning.

  In addition to the board meetings during the year, the Board held a number of ad hoc meetings and a strategy session with presentations from senior management.

  its duties and responsibilities effectively. Ыe Non-Executive Directors, with the exception of Max Royde, are considered to be independent, and no individual or group of individuals is dominant in the decision-making process. Ыe Directors have complementary skills and experience in terms of sectors, geography and diversity. Ыe biographical details of the current Directors, including their skills and experience, are set out on pages 41 and 43.

  Chairman

  Ыe role of the Chairman is separate to, and independent of, the Chief Executive and each role has clearly defined responsibilities. Ыe role of the Chairman has adequate separation from the day-to-day business of the Company in order to

  facilitate independent decision making. Christopher Satterthwaite is responsible for effective leadership of the Board and ensuring the efficient management of the following:

• to establish the vision, mission and values of the Group;

• to set strategic objectives and provide the leadership to put them into effect;

  Ыe Chairman sets the Board's agendas, in

  consultation with the CEO and Company Secretary, taking full account of the need to allow time for robust and constructive discussion and challenge on all relevant matters. He is responsible for promoting effective communication between the Board and

  its Directors, in and outside of Board meetings, and for seeking engagement with major shareholders to understand their views on governance and

  performance against the strategy agreed by the Board.

  Ыe Chairman has a close working relationship with the CEO and the Company Secretary, who work together to monitor the effective implementation of the strategies and actions agreed by the Board.

  Chief Executive Officer

  Ыe CEO is responsible for implementing the Group's strategy and for the financial performance, risk management, people development and other key components of ongoing operations. Ыe CEO is also responsible for recruitment, leadership and development of our executive management team and for proposing to the Board our approach to vision, values, culture, diversity and inclusion.

  48 Environmental, Social and Corporate Governance 49 Environmental, Social and Corporate Governance

  Corporate governance

  Chief Financial Officer

  Ыe Chief Financial Officer (CFO) is responsible for the financial management of the Group and its financial reporting, for monitoring our operating and financial results and for management of our internal financial control systems. Ыe CFO also has responsibility

  for oversight of liquidity management, and the management and safeguarding of the Group's assets. He supports the CEO in implementing our strategy and in relation to the financial, risk management and operational performance of the Group.

  Senior Independent Director

  Ыe Senior Independent Director (SID) acts as a sounding board for the Chair and is available to act as an alternative line of communication between the shareholders and the Board.

  Non-Executive Directors

  Ыe Non-Executive Directors are independent of

  Director independence

  In line with the requirements of the QCA Code, determining director independence is a Board judgement and is reviewed on an annual basis as part of the approval process for the Annual Report and Accounts. Ыe Board considers factors such as length of tenure and relationships or circumstances that

  are likely to affect, or appear to affect, the Directors' judgement in determining whether they are and remain independent.

  Ыe Board has reviewed the independence of each Non-Executive Director and all Non-Executive Directors, excluding Max Royde, are considered to be independent. Max Royde, who represents our

  shareholder, Kestrel Partners LLP, is fully independent of management but is not considered independent.

  Further details of the relationship agreement under which Max has been appointed to the Board, can be found on page 50.

  Board Evaluation

  Ыe QCA Code states that the Board should regularly review the effectiveness of its performance as a unit, as well as that of its Committees and the individual Directors. Accordingly, the Board undertakes internal effectiveness reviews on an annual basis. Ыe findings were presented to the Board in February 2026. Ыe Board considered the final report, and the recommendations were shared with each Committee. An action plan for areas of further focus was agreed.

  Ыe Chair reviews the performance of individual Directors regularly. Ыese reviews confirmed that each Director makes an effective and valuable contribution and continues to demonstrate commitment to their role.

  Ыe key findings following the 2025 review are as follows:

  Succession Planning

  Ыe Board has retained responsibility for succession planning and, accordingly, has not established a Nomination Committee. Ыe Board regularly reviews its composition and may utilise performance evaluations when considering composition or succession planning.

  Ыe Board uses succession planning to ensure that executives with the necessary skills, knowledge and expertise are in place to develop and deliver our strategy, and that it has the right balance of

  individuals to be able to discharge its responsibilities. Any searches for Board candidates and appointments made are based on merit against objective criteria, including the use of a Board skills matrix. Ыe Board as a whole is also involved in overseeing the development of management resources across the Group.

  Induction, training and development

  Orientation for all new Non-Executive Directors includes:

  management and are considered by the Board to be free from any business or other relationships that could compromise their independence. Ыeir role is to effectively advise and constructively challenge management, along with monitoring management's success in delivering the strategy within the risk

  appetite and Control Framework agreed by the Board. Ыey are also responsible, through the Remuneration Committee, for determining appropriate levels of remuneration and reward for the Executive Directors.

  Company Secretary

  Ыe Company Secretary, Beyond Governance Limited, supports and works closely with the Chairman, the CEO, the CFO and the Board Committee Chairs and supports the Group's decision-making processes by attending and minuting the meetings of the Board and its Committees. Ыe Company Secretary also advises the Board on corporate governance matters and Board procedures, particularly regarding the Group's statutory and regulatory obligations.

  NED Time Commitment

  Each Director commits an appropriate amount of time to discharge their duties effectively during the financial year, this includes preparing for and

  attending scheduled Board and Committee meetings, as well as other meetings or calls as necessary.

  Ыe Non-Executive Directors met the expected time commitment of at least two days per month on Company business pursuant to their letters of appointment. Where Directors are unable to attend

  meetings, they are encouraged to give the Chairman their views in advance on the matters to be discussed.

  Ыe Board is satisfied that each of the Directors continues to be able to allocate sufficient time to the Company to discharge their responsibilities effectively, notwithstanding changes to the external commitments of certain Directors.

  Focus area

  Competitor performance

  Succession planning

  Succession planning

  Theme

  Ыe Board to have oversight of the analysis of the performance of the Group's competitors

  Ыe Board to review and have appropriate oversight of executive

  succession

  Ыe Board to have visibility of potential successors for key management positions within the business

  Actions

  Management reporting reflecting competitor landscape and performance compared to peers is included within the annual meeting planner for consideration by the Board

  in 2026

  Ыe Company maintains an annual meeting planner which highlights the key topics to be covered by the Board and its Committees throughout the year.

  Executive Succession Planning is included within the 2026 planner for consideration by the Board

  As part of the continued development of succession plans for the organisation, development of a talent pipeline matrix for key management positions is being captured through executive reporting.

• AIM Regulatory Rules presentation from Cavendish;

• Introduction to the Company Secretarial role and training on the Share Dealing Policy from Beyond Governance;

• Strategic Overview from the CEO covering Group strategy and product outline, organisational structure and key roles and investor relationships, and

• Product demonstrations.

  Additional sessions are scheduled as appropriate to cover product development or financial performance in more detail. In order to facilitate greater awareness and understanding of our business and operating environment, all Directors are given regular updates on changes and developments in the business between the scheduled Board meetings.

  Training opportunities are provided through internal meetings, workshops, presentations and briefings

  50 Environmental, Social and Corporate Governance 51 Environmental, Social and Corporate Governance

  Corporate governance

  by internal advisers and business heads, as well as external advisers. Ыe Company Secretary updates the Board on any relevant legislative and regulatory corporate governance-related changes on a regular basis.

  Ыe Directors meet with executives to receive further insights into the operations of the business in the jurisdictions where the Group operates. Ыe Chairman ensures that the Directors continually update and refresh their skills and knowledge, and independent professional advice is provided, when required, at the Group's expense.

  Internal Control

  Ыe Board acknowledges that it has ultimate responsibility for the Group's system of internal control and has delegated the review of its effectiveness to the Audit Committee. Such systems are designed

  to manage rather than eliminate risks and can only provide reasonable not absolute assurance.

  Ыe Board routinely reviews the systems of internal control and risk management having particular regard to the need to embed internal control and risk management procedures into the operations of business, both in the UK and overseas, and to deal with areas of improvement which come to management and the Board's attention.

  Delegated authorities

  Ыe Board has delegated authority for certain matters to the Audit Committee and Remuneration Committee, both of which have terms of reference which are reviewed annually. Certain operational responsibilities have been delegated to the Executive team and senior management within a robust system of control. Ыe schedule of matters reserved for the Board is available on the Group's website.

  Shareholders

  Ыe Board

  Responsible for providing leadership, including setting the Group's strategic direction, purpose and values, and promoting its long-term success. A full schedule of matters reserved for the Board is available on the Company's website

  Committees

  To ensure that it maintains an appropriate level of oversight, the Board has established committees to support it. Ыe terms of reference for the Audit and Remuneration Committees are available on the Company's website.

  Audit Committee

  Remuneration Committee

  Oversees the Group's financial reporting and disclosures. It also oversees the Group's system of internal controls and risk management systems and

  the external audit.

  Responsible for determining executive remuneration policies and practices, taking account of pay practices and policies across the Group's workforce and alignment with delivery of the Company's

  strategic objectives.

  Conflicts of Interest

  Directors have a statutory duty to avoid conflicts of interest. All Board members must promptly notify the Chairman and Company Secretary in advance of any matters where there is a reasonable likelihood that such matters could give rise to an actual or perceived conflict of interest to identify and manage conflicts of interest. Ыis would include, but is not limited to, other Executive roles and directorships, or material shareholdings in companies that may compete with

  the Group or which may have a customer or supplier relationship with the Group or which may benefit from investment by the Group.

  Under our Agreement with Kestrel Partners LLP, Kestrel is entitled to nominate an individual for appointment to the Board. Ыis is conditional upon Kestrel retaining an interest in shares in the Company (representing approximately 28.25% of issued share capital).

  During the period to 30 November 2025, no other Director had a material interest at any time, in

  any contract of significance with the Company or Group other than their service contract or letter of appointment. However, should a conflict arise, Board members would withdraw from any consideration of the matter by the Board and, in the event that the matter related to competition, may be required to resign from the Board. No conflicts of interest arose during the year.

  Documents available on the website

• Matters Reserved for the Board

• Application of the QCA Code

• Audit Committee Terms of Reference

• Remuneration Committee Terms of Reference

• Memorandum and Articles of Association

Framework for Corporate Governance

Ыe Board recognises the importance of good corporate governance as one of the foundations of a sustainable corporate growth strategy and sound decision making and has established a corporate

governance model based on the key principles of the QCA Code.

Ыe Non-Executive Chairman, Christopher Satterthwaite, has ultimate responsibility for

leadership of the Board and, the quality of, and the Group's approach to, corporate governance. Our strong governance structure has continued to provide a firm base from which the Group, led by the Board, could respond to the unprecedented challenges and protect the long-term interests of our stakeholders during this extended period of uncertainty.

Nomination Committee

Ыe Board has retained responsibility for the structure, size and composition of the Board and has therefore has not established a Nomination Committee. Given the size of the Group, these duties are effectively carried out by the Board.

The Audit Committee

Ыe Audit Committee is chaired by Sarah Vawda and its other member is Christopher Satterthwaite. Ыe Board has delegated responsibility to the Audit Committee for monitoring the integrity of the financial statements of the Group, and monitoring

and reviewing the adequacy and effectiveness of the Group's internal financial controls. It also monitors the risk management systems, reviews and assesses the overall risk appetite, tolerance and strategy, and the principal and emerging risks the company is willing

to take in order to achieve its long-term strategic objectives. Further information can be found in the Audit Committee Report on pages 77 to 81.

The Remuneration Committee

Ыe Remuneration Committee is chaired by Chris Pilling and its other member is Christopher Satterthwaite. Ыe Board has delegated authority to the Remuneration Committee which has primary responsibility for reviewing the performance of the Directors and setting their remuneration, including any share options. Ыe Committee ensures the Directors are rewarded fairly and responsibly, with a clear link to both corporate and

52 Environmental, Social and Corporate Governance 53 Environmental, Social and Corporate Governance

individual performance, while also considering legal and regulatory requirements. Further information can be found in the Remuneration Committee Report on

page 83.

Compliance with the QCA Code

long-term success, the Board has continued to apply the principles in the QCA Code as the most appropriate governance model for the Group. Ыe following demonstrates how each of those ten principles has been addressed:

Principle Application Further Details

3.

During the year, in support of the Group's medium to

Principle Application Further Details

Deliver growth 1.

Take into account wider stakeholder and social responsibilities and their implications for long-term success

Ыe Board considers its key stakeholders to be its employees, customers, shareholders, suppliers and the communities and environment in which it operates. Consideration of our stakeholders' feedback is fundamental to our key business decision-making and the formulation of strategy. Ыe Group takes its corporate social responsibilities seriously and continuously works to strengthen relationships with all its stakeholders.

To find out more see our Section 172 statement in the Strategic Report on pages 33 to 36 and our Environmental,

Social and Governance Report on pages 61

to 67.

Establish a strategy and business model to

promote long-term value for shareholders

2.

Seek to understand and meet shareholder needs and expectations

Ыe Group's strategy and business model are designed to promote longterm value for shareholders and stakeholders by maintaining the Company's position as a martech leader. Ыe strategy and business model are developed by the Chief Executive Officer, Chief Financial Officer and senior management team, and approved by the Board in line with the Group's vision and mission. Progress is actively tracked and debated by the Directors and the Board received a number of strategic updates throughout the year. Ыe senior management team, led by the Chief Executive Officer, is responsible for their effective delivery and implementation.

Ыe Board places great importance on having positive, sustainable relationships with all shareholders and seeks to ensure that an appropriate and proactive level of dialogue is in place. Ыe Executive Directors have primary responsibility for engagement with shareholders and operate a regular programme of investor engagement which includes presentations following the announcement of financial results, which are published on the Group's website to ensure they can be accessed by all shareholders. Ыe Executive Directors provide regular updates to the Board on the outcome of shareholder meetings to ensure that the Board is kept up to date and aware of shareholder's views. Extensive engagement with shareholders was undertaken throughout 2025, particularly following the release of trading updates, interim and full year results. Ыese sessions were constructive and enabled more detailed explanations of the Group's strategic plan.

Ыe AGM provides an important opportunity for shareholders to engage directly with the Board and enables shareholders to ask questions on the business of the AGM and the performance of the Group.

Contact details for shareholders are available on the Group's website to support open channels of communication and feedback.

Ыe Group's strategy, business model and linked key performance measures are set out within the Strategic Report on pages 23

to 36.

Please refer to our Section 172 Statement in the Strategic Report on pages 33

to 36 for more detail on the focus we apply to shareholder engagement and investor relations

to ensure that the Group's performance and strategy are clearly understood.

4.

Embed effective risk management, considering both opportunities and threats, throughout the organisation

Ыe Board has ultimate responsibility for the Group's risk management process which is supported by the Audit Committee. Ыe Board is responsible for the identification and evaluation of risk and for ensuring that the Group has appropriate systems and controls in place for effective risk management. Ыe Group's policy on risk management covers all significant business risks to the Group, including financial, operational and compliance risks that could be barriers to achieving our business objectives.

Ыe Board monitors risk and control processes across headline risk areas and other business-specific risk areas. At each Board meeting Group performance is reviewed, including both financial and non-financial key performance indicators ("KPIs"), as well as the consideration of new threats and opportunities presented to the Group.

Ыe Group has formalised its risks into a risk register which is designed to provide the Board with a consistent, Group-wide perspective of the key risks. Whilst the Board is ultimately responsible for risk, our culture seeks to empower all employees to manage risk effectively.

Ыe Group's controls are designed to manage risks rather than eliminate them. Mitigation can only provide reasonable, but not absolute, assurance against material misstatement or loss. As such the Group maintains appropriate insurance cover for its activities, with the types of cover and insured values being reviewed on a periodic basis by the Board.

Ыe risk register is formally reviewed by the Board and the Audit Committee annually and the Group's principal risks and explanations

of how these are mitigated are set out on pages 27 to 32.

Internal control and risk management systems are reviewed regularly by the Audit Committee, for further information see the Audit Committee report on pages 77

to 81.

54 Environmental, Social and Corporate Governance 55 Environmental, Social and Corporate Governance

Principle Application Further Details Principle Application Further Details

Maintain a dynamic management framework

5.

Maintain the Board as a well-functioning,

balanced team led by the Chair

6.

Ensure that between them the Directors have the necessary up to date

Our Board of Directors comprises a Non-Executive Chairman, a Senior Independent Director, one independent Non-Executive Director, one non-executive director and two Executive Directors. Christopher Satterthwaite, as Non-Executive Chairman, is responsible for leading the Board and for both

the quality of and approach to corporate governance. Joanna Arnold, as Chief Executive Officer, is responsible for running the business and implementing the Group's strategy. Sarah Vawda as Senior Independent Director acts as

an independent sounding board for the Chair and as an alternative line of communication between the shareholders and the Board.

Ыe Board considers itself to be adequately resourced to discharge its governance responsibilities and sufficiently independent, in compliance of the QCA Code. Chris Pilling as a Non-Executive Director is considered to be independent by the Board. Max Royde is a Non-Executive Director and is not considered to be independent as he is the CEO of Kestrel Partners LLP who is

a substantial investor in the Group holding 28.84% of the issued share capital. Non-Executive Directors are required to spend at least two days per month on Company business. Ыe Board follows a pre-approved annual schedule of meetings and during the year met 12 times.

Ыe Board has a formal schedule of matters reserved for its approval and is supported in its work by an Audit Committee and a Remuneration Committee which are each chaired by an Independent Non-Executive Director. Ыe full schedule of matters reserved for the Board is available on our website www. pulsargroup.com/investors. Ыe Board has not appointed a Nomination Committee, that given the size of the Group, the Board size, structure and composition can be effectively set by the Board.

Ыe Board works as a team exploiting its members' in-depth experience of strategy, technology, international and financial matters. Meetings are characterised by debate and active idea generation and management are rigorously challenged and held to account.

All Directors are subject to election by shareholders at the first AGM following their appointment to the Board and Directors seek re-election at least once every three years thereafter. Max Royde, Christopher Satterthwaite and Chris Pilling were reappointed at the AGM in 2025.

Ыe Board regularly reviews its composition to ensure that it has the necessary breadth and depth of skills to support the ongoing development and growth of the business. Ыe Board is satisfied that it has a suitable mix of

Ыe biographies of all the Board members are set out on pages 41 to 43.

Details of Board composition, Directors' roles and responsibilities and NED time commitment are set out on pages 49 to 51.

For board meeting attendance information see the table on page 48. Further details of the responsibilities and composition

of the Audit and Remuneration Committees are set out on page 53.

Biographies of the Directors are provided on pages 41 to 43.

experience, skills and capabilities

7.

Evaluate Board performance based on clear and relevant objectives, seeking continuous improvement

skills and competencies covering all essential disciplines to bring a balanced perspective that is beneficial both strategically and operationally, enabling the Group to deliver its strategy for the benefit of its shareholders over the medium to long-term.

Where new Board appointments are considered, the search for candidates is conducted and appointments are made on merit, against objective criteria and with due regard for the benefits of diversity on the Board, including but not limited to gender balance.

Ыe Directors keep their skillset up to date with ongoing training, attending business conferences and briefings, and are individually assessed on an annual basis through the annual performance evaluation process through which their performance against predetermined objectives is reviewed, and their personal and professional development needs are considered. Ыe Directors are kept abreast of changes in relevant legislation and regulations, with the assistance of the Group's advisers where appropriate.

In addition, the Board members have had full access to the services of the Corporate Secretary, a role carried out by Beyond Governance Limited who provide expert advice to the Board. Each Director is aware of the right to have any concerns minuted and to seek independent advice at the Group's expense where appropriate.

Ыe Board and its committees undertake a performance evaluation annually, taking into account the Financial Reporting Council's Guidance on Board Effectiveness. An evaluation of the Board and Committees performance was conducted during the year facilitated by the Corporate Secretary, Beyond Governance Limited, which involved observation and assessment of the Board and its committees in operation as well as completion of a detailed questionnaire by each Director. Ыe criteria assessed as part of the evaluation included succession and capacity planning in addition to Board and committee composition.

Ыe Board regularly reviews its composition, particularly in conjunction with succession planning, and may utilise the results of performance evaluations when considering this composition and/or succession planning. Succession is seen as a vital task for the Board and is regularly reviewed.

All Directors undergo a performance evaluation before being proposed for

re-election to ensure that their performance continues to be effective, where appropriate that they maintain their independence, and that they demonstrate continued commitment to the role. Formal performance reviews are carried out annually with all Executive Directors.

Details of the key findings of the 2025 Board

Evaluation can be found on page 51.

56 Environmental, Social and Corporate Governance 57 Environmental, Social and Corporate Governance

Principle Application Further Details Principle Application Further Details

8.

Promote a corporate culture that is based on ethical values and behaviours

9.

Maintain governance structures and processes that are fit for purpose and support good decision-making by the Board

Ыe Board seeks to promote and maintain a culture of integrity across all businesses within the Group and to ensure that the highest standards of integrity and ethics are demonstrated through the Company's objectives, strategy and business model. Ыese standards are enshrined in the Group's written policies which are accepted by all employees and reviewed during the annual performance review.

An open culture is encouraged within the Group, with employee feedback sought and regular progress and performance updates provided to all employees. We run a people and talent management programme which together with in-person and virtual Town Hall presentations and training have provided additional opportunities for the Board to promote and monitor a healthy corporate culture.

Ыe long-term success of the Group is the responsibility of the Board of Directors, which comprises three independent Non-Executive Directors, one Non-Executive Director and two Executive Directors. Ыe Executive Directors have responsibility for the operational management of the Group's activities. Ыe Non-Executive Directors are responsible for bringing independent and objective judgement to Board decisions.

Ыe Board considers that the Company's governance structures are appropriate for the size, complexity and risk profile of the Company. Governance arrangements will be reviewed as and when required to ensure they remain appropriate.

Ыe Chairman has ultimate responsibility for the operation, leadership and governance of the Board. Ыe Chief Executive Officer has ultimate

responsibility for implementing and delivering the strategic and commercial objectives of the Board and managing the day-to-day business activities of the Group. Ыe Corporate Secretary is responsible for ensuring that Board procedures are followed, and applicable rules and regulations are complied with.

On a regular basis, the Board reviews the schedule of matters reserved for the Board, and each Committee reviews its terms of reference to ensure they remain fit for purpose and support good decision-making.

Ыe Board has established two committees, an Audit Committee and a Remuneration Committee, with formal terms of reference (which are available on our website https://www.pulsargroup.com/investors). Each Committee is chaired by an independent Non-Executive Director. Membership of both Committees

See further details of our behaviours in the Business Overview on page 7.

Corporate Governance report on pages 47 to 59.

Audit Committee Report on page 77 and the Remuneration Committee Report on page 83.

Build Trust

10.

Communicate how the Company is governed and is performing by maintaining a dialogue with shareholders

and other relevant stakeholders

during the year under review was comprised exclusively of independent Non-Executive Directors.

Ыe Board receives support and information from the executive management team and the Group's senior managers.

Ыe Board recognise the importance of providing shareholders with clear and transparent information on the Group's activities, strategy and financial position and does so in a number of ways, including:

• the Group's Annual Report and Accounts;

• full year and half year announcements;

• other regulatory announcements;

• the Annual General Meeting;

• update meetings with existing shareholders; and

• disclosure of all votes in a clear and transparent manner.

A range of corporate information, including annual reports for the last five completed financial years, full and half year results announcements, notices of General Meetings for the last five completed financial years and other regulatory announcements, is also available to shareholders, investors and the public through the Group's website.

See the details included under Principle 2 above regarding how the Company maintains an active dialogue with its shareholders on the Group's performance. A range of information can be found on

the Company's website https://www. pulsargroup.com.

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Environmental, Social and Governance Report

Our strategy for ESG

In today's business environment, we believe that setting and delivering against a clear Environmental, Social, and Governance (ESG) Strategy is an important benchmark for how a responsible organisation

should operate. We consider it important that the ESG strategy is embedded throughout the business so that all stakeholders can see that there is a real commitment to its achievement, both at Board level and across the organisation.

A key focus of the Group is in expanding areas of its products and services that help to reduce inequality and/or help customers to improve their own ESG performance. Positive examples of this include but are not limited to:

• Reducing inequality through a deep-rooted understanding of audiences. Ыe audience intelligence capabilities of our products promote diversity and inclusion, for example by allowing government clients to understand their different communities.

• Helping customers to understand bias and misinformation in news reporting through our platform with partnerships such as Newsguard. Ыis allows them to take positive actions to reduce the impact of such bias or misinformation.

• Providing insights services to customers which allow them to understand bias within and around their organisations. A good example of this is a report undertaken in conjunction with Sport New Zealand to understand gender bias across sport media coverage in Aotearoa New Zealand.

  • Enabling customers to make better decisions around their own ESG strategies through understanding the key ESG related issues that are

most important to their own stakeholders.

Ыe Board has also determined that initiatives should be promoted across the Group to support a broad spectrum of diversity, including but not limited to: age, culture, disability, gender, race and ethnicity, sexual orientation, and social demographic.

Pulsar Group has an approved ESG strategy, formalising a lot of the excellent work that has been undertaken across the business to date and ensuring that ESG activities are sponsored and discussed at Board level.

Ыere were three main areas that Pulsar Group focused on in the development of its ESG strategy:

• Reviewing the expectations of key stakeholders in respect of ESG matters, including customers, employees and investors, in addition to a review of the ESG initiatives and reporting of companies within our industry that are considered to be high performers from an ESG perspective.

• Reviewing publicly available frameworks to identify key areas of ESG focus and reporting for the Group.

• Developing a set of key actions to be delivered as part of the Group's ESG Strategy.

  Ыis ESG report outlines:

• Ыe key areas of focus identified by Pulsar Group as part of its ESG strategy and ongoing initiatives to support these.

• A set of key actions that the Group intends to deliver as part of its ESG strategy.

• Disclosures in respect of Diversity, Equity and Inclusion ('DEI') and climate related matters.

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Environmental, Social and Governance Report

Key areas of ESG focus for Pulsar Group

A wide range of stakeholders use ESG frameworks and reporting to inform a wide range of decisions. As part of the development of its ESG strategy, Pulsar Group reviewed SASB Standards, which guide the disclosure of financially material sustainability information by companies to investors and other stakeholders. Using the SASB Materiality Finder, six relevant issues were identified for the Software & IT services industry in which the Group operates:

• Environment - impacts associated with energy consumption, from utility providers but also energy efficiency and intensity.

• Employee engagement, diversity and inclusion - ensuring that culture, hiring and promotion practices embrace the building of a diverse and inclusive workforce that reflects the makeup of local talent pools and customer base.

• Customer privacy - risks related to the use of personally identifiable information (PII) and other customer or user data.

• Data security - risks related to collection, retention, and use of sensitive, confidential, and/or proprietary customer or user data.

• Systemic risk management - systemic risks resulting from large-scale weakening or collapse of systems upon which the economy and society depend, including financial, natural resource and technological systems.

• Competitive behaviour - social issues associated with existence of monopolies, which may include, but are not limited to, excessive prices, poor quality of service, and inefficiencies.

Alignment of our ESG strategy with UN Sustainable Development Goals

Alongside the SASB standards and materiality map, Pulsar Group has elected to incorporate actions within its ESG strategy which are aligned to a number of the UN Sustainable Development Goals (SDGs). Ыe SDGs are a set of 17 aims created to pave the way for peace and prosperity for the planet and its people, with five of the SDGs considered by the Group to be closely aligned with its overall strategy and working practices. Ыe SDGs incorporated within the Group's ESG strategy are as follows:

Achieve gender equality and empower all women

Relevant targets for Pulsar Group

5.5 - Ensure women's full and effective participation and equal opportunities for leadership at all levels of decision-making in political, economic and public life.

Relevant targets included within ESG strategy

• Recruitment and Board make-up - work has been done over the last few years to diversify the makeup of the executive Board.

• Maternity pay package - the company goes above statutory requirements for maternity pay to ensure that women feel supported in taking maternity leave.

Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all

Relevant targets for Pulsar Group

8.5 - By 2030, achieve full and productive employment and decent work for all women and men, including for young people and persons with disabilities, and equal pay for work of equal value.

8.7 - Take immediate and effective measures to eradicate forced labour, end modern slavery and human trafficking and secure the prohibition and elimination

of the worst forms of child labour, including recruitment and use of child soldiers, and by 2025 end child labour in all its forms.

Relevant actions included within ESG strategy

• Equal pay for equal value - Pulsar Group is committed to providing equal pay to employees within countries performing the same role, regardless of gender, race, religion or other status.

• Modern Slavery Policy - the Group refreshed and relaunched its modern slavery policy to better reflect the size and structure of the global business. Ыe aim of the policy is to inform all employees about modern slavery and make them aware they have an obligation to report in good faith any suspicions that modern slavery may be taking place.

• Ыis is in addition to a review of suppliers: the countries they are based in, minimum wage thresholds and relevant legislation. We do not enter into business with any other organisation which knowingly supports or involves itself in slavery, servitude or forced labour. No labour used by us

  in the provision of our own services to clients is obtained by means of slavery or human trafficking.

• Whistleblowing - an updated whistleblowing policy was approved by the Board in September 2024 and

  62 Environmental, Social and Corporate Governance

  63 Environmental, Social and Corporate Governance

  operates across the Group.

  Environmental, Social and Governance Report

  Reduce inequality within and among countries

  Relevant targets for Pulsar Group

• 10.2 - By 2030, empower and promote the social, economic and political inclusion of all, irrespective of age, sex, disability, race, ethnicity, origin, religion or economic or other status.

• 10.3 - Ensure equal opportunity and reduce inequalities of outcome, including by eliminating discriminatory laws, policies and practices and promoting appropriate legislation, policies and action in this regard.

  Relevant actions included within ESG strategy

• Board representation - Ыe Institutional Shareholder Services Group has stated that each AIM company should have at least one director from an ethnic minority by 2024, a position we are pleased to have complied with. As part of the selection of new Directors we pro-actively ensure that the search process is sufficiently inclusive to encourage applications from diverse candidates

  with relevant skills, experience and knowledge, and that the selection process is fair and transparent.

• Pulsar Group LGBTQ+ Network - the network was created in April 2022 to represent and advance the cause of LGBTQ+ rights both internally and externally and to provide a safe space for our LGBTQ+ employees.

• Flexible cultural days - in 2024, Pulsar Group introduced flexible cultural days, allowing employees to swap in/out national public holidays which don't fit their particular values, beliefs or heritage.

  Ensure sustainable consumption and production patterns

  Relevant targets for Pulsar Group

• 12.5 - By 2030, substantially reduce waste generation through prevention, reduction, recycling and reuse.

• 12.6 - Encourage companies, especially large and transnational companies, to adopt sustainable practices and to integrate sustainability information into their reporting cycle.

  Relevant actions included within ESG strategy

• Water fountains & coffee machines - the company provides water fountains & coffee machines for employees to use to minimise the use of single-use plastics.

• Recycling bins - the company uses recycling bins for glass and plastic where single-use plastics cannot be avoided.

• Recycling water - within the Sydney building a 15,000 litre rainwater storage tank provides

  rainwater for on-site drip irrigation and fire water reuse tank allows recycled water to be utilised for the testing of the building fire system.

• Waste management policy - the Group is committed to reducing waste generation by developing a Group wide waste management policy for the first time which will not only commit to a plan to reduce waste in our offices, but also to educate employees on how to make changes in their own lives.

• Moved our UK head office during FY24, to an office almost half the size, to improve our ESG footprint.

• Take urgent action to combat climate and its impacts

  Relevant targets for Pulsar Group

• 13.2 - Integrate climate change measures into national policies, strategies and planning.

  Relevant actions included within ESG strategy

• Cycle to work scheme - Pulsar Group continues to offer a cycle to work scheme, encouraging employees to replace their usual modes of transport to work with cycling. We also provide bike storage and end-of-trip facilities to support both the health and wellbeing of our people.

• Carbon reduction - as an interim solution while we work towards our net zero plan, the Group is looking to develop credible actions to support emissions reduction. Ыe Group also continues to use energy efficient lighting in its two largest offices, London and Sydney.

• Partnership with SCAPE - Ыe Insights team in Singapore partnered with SCAPE, a nonprofit organisation that supports youth, talent and leadership development, to develop

and co-ordinate "Hacking Ыe NewNormal SUSTAINABILITY". Ыis was a growth hackathon in a virtual environment that provided a platform for young people in teams of 3-7 to work with industry mentors to gain practical experiences of problem solving and develop their understanding of key environmental challenges related to Food Security, Reduced Pressure on Livestock, Zero Wastage, Clean Tech and Sustainable Urban Planning and Mobility.

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Environmental, Social and Governance Report

Key actions identified as part of the Group's ESG strategy

• In the development of the Group's ESG strategy, a number of key actions were identified that

  the Group intends to deliver. Ыese have been separated into short, medium and long term actions:

  Short term < 1 year

• Refreshing and reissuing Group policies relating to a range of ESG matters including: anti-bribery/corruption, anti-slavery/child labour, climate change/carbon reduction, data privacy, diversity, ethics, training and development, waste management, and whistle blowing.

• Finalising a new supplier code of conduct.

  Medium term 1 - 3 years

• Setting credible carbon reduction goals in line with the SBTi. Ыis will need to include proposed actions to achieve the carbon reduction goals.

• Agree a proposed timetable for the Group to achieve Net Zero carbon reduction goals

  Long term 3+ years

• Achieving Net Zero.

  Ыe following sections of this report show how Pulsar Group is currently performing against these goals and how it intends to meet them in the future.

  Performance against short and medium actions It is intended that the short-term actions will have been completed within the next 12 months, with some progress having already been made:

• Pulsar Group does not currently generate scope 1 emissions and is already seeking opportunities to reduce its scope 2 emissions through more efficient office space usage.

• Pulsar Group track scope 3 emissions and make efforts to reduce these year on year.

• Revised Group policies in respect of ESG matters and a new supplier code of conduct are being developed and will be formally issued to the business.

Further work will be undertaken during 2026 on these actions and an update on progress against them will be provided in the Group's next Annual Report.

Diversity, Equity and Inclusion related disclosures

We believe that at Pulsar Group, having a diverse and inclusive working environment is key to solving the problems of tomorrow. Allowing our employees to feel comfortable expressing themselves at work is how we believe that we can get the best out of them. To reflect the diversity of our work place, in 2024, Pulsar Group introduced flexible cultural days, allowing employees to swap in/out national public holidays which don't

fit their particular values, beliefs or heritage. Ыis allows employees from all backgrounds to feel like the company recognises their contribution and is putting them at the forefront of our progress.

At 30 November 2025, the Group had 33% female directors, including a female CEO. In addition, we are pleased to have one director from an ethnic minority background.

At 30 November 2025, our split of employees by region and by reported gender* was as follows:

	Female	Male	Non-Binary	Total	%Female	%Male	Non-Binary
EMEA **	87	83	1	171	51%	49%	1%
USA & Canada	6	3	0	9	67%	33%	0%
Australia	61	74	2	137	45%	54%	1%
New Zealand	21	10	3	34	62%	29%	9%
Indonesia	15	10	0	25	60%	40%	0%
Malaysia	46	20	0	66	70%	30%	0%
Philippines	157	118	3	278	56%	42%	1%
Singapore	10	7	0	17	59%	41%	0%
Thailand	10	7	0	17	59%	41%	0%
Vietnam	20	5	0	25	80%	20%	0%
TOTAL	433	337	9	779	56%	43%	1%

* In situations where colleagues have not disclosed gender, these have not been included within reported numbers

** EMEA primarily comprises the UK, with a small number of colleagues located in other EMEA countries.

66 Environmental, Social and Corporate Governance 67 Environmental, Social and Corporate Governance

Task Force on Climate Related Financial Disclosures

Ыe Group is committed to monitoring and reporting ethnicity as part of its Diversity, Equity and Inclusion efforts and has undertaken a project to capture global employee ethnicity data on a voluntary basis. Ыis includes obtaining relevant ethnicity data when onboarding new employees as well as a wider survey of existing employees. Ыe results of this project are outlined in the table below.

data for these has been obtained from the respective building management companies in kWh and converted to GJ and CO2e using the aforementioned GHG Protocol conversion factors.

Previously, in order to improve energy efficiency and reduce carbon footprint, we introduced innovations in recycling and office waste, encouraging take up of low impact transports including cycle to work schemes, walking to work and investing in sustainable and

EMEA & NA

APAC
Non-ethnic minority	80
Ethnic minority	3
Prefer not to disclose	17

Non-ethnic minority Ethnic minority Prefer not to disclose

% of Respondents

46

13

41

low-carbon-cost office design to deliver long term benefits. We are currently creating a new Group-wide ESG committee, where representatives from each country within the Group will be able to feedback ideas about how to improve sustainability in their individual offices to a Board appointed representative. In addition, while the Group works towards a net zero transition plan, we are looking for credible, impactful offsetting projects to support, in addition to our commitment to emissions reduction.

Climate-related financial disclosures

At Pulsar Group we are committed to responsible carbon management and reducing our carbon footprint throughout the organisation. As such, we have taken the decision to disclose our global carbon emissions, going above and beyond the expectations of the Streamlined Energy and Carbon Reporting disclosures, where only UK information is mandatory. Ыe figures in the below table were calculated based on Government Greenhouse Gas Protocol conversion factors and in line with acceptable SECR methodology, specifically the GHG Protocol Corporate Standard.

Due to the nature of the organisation, the business does not generate scope 1 emissions, and so there are only scope 2 and scope 3 emissions to report. Usage

Ыe Group is in scope of Climate Change Regulation please see page 75 for our metric and targets section of the Task Force on Climate Related Financial Disclosures section of the report for detailed figures.

68 Environmental, Social and Corporate Governance

69 Environmental, Social and Corporate Governance

Task Force on Climate Related Financial Disclosures

We set out below our climate-related financial disclosures consistent with all of the TCFD recommendations and recommended disclosures. By this we mean the four TCFD recommendations and the 11 recommended disclosures set out in the report entitled "Recommendations of the Task Force on Climate-related Financial Disclosures" published in June 2017 by the TCFD.

Pulsar Group has naturally lower direct carbon emissions than other sectors due to the nature of its operations, with a sizable majority of its greenhouse gas ("GHG") emissions coming from the use of leased business premises and the purchasing and use of data and IT infrastructure/software from third

party suppliers. Ыe Group has little control over the emissions produced by these third parties. Although the GHG use of leased business premises that we have direct control over are not significant, we have continued to take actions, e.g. continue to identify opportunities to use lower carbon-based suppliers where possible, throughout the year to reduce them and are developing plans to speed up this reduction (see the Strategy section for more information).

TCFD Framework		Page /comply	Next steps
Governance	a) Describe the Board's oversight of climate-related risks and opportunities.	Page 69	Compliant
	b) Describe Management's role in assessing and managing climate- related risks and opportunities	Page 69	Compliant
Strategy	a) Describe the climate-related risks and opportunities the organisation has identified over the short, medium, and long term.	Page 72	Compliant
	b) Describe the impact of climate-related risks and opportunities on the organisation's businesses, strategy, and financial planning.	Page 74	Compliant
Risk Management	a) Describe the organisation's processes for identifying and assessing climate- related risks.	Page 74	Compliant
	b) Describe the organisation's processes for managing climate- related risks	Not yet compliant	Formalise an approac on how we formalise climate related risk management in the future
	c) Describe how processes for identifying, assessing, and managing climate-related risks are integrated into the organisation's overall risk management.	Not yet compliant	Formalise an approach on how we integrate climate related risk into the overall risk management
Metric and Targets	a) Disclose the metrics used by the organisation to assess climate- related risks and opportunities in line with its strategy and risk management process.	Page 75	Compliant
	b) Disclose Scope 1, Scope 2, and, if appropriate, Scope 3 greenhouse gas (GHG) emissions, and the related risks	Page 75	Compliant
	c) Describe the targets used by the organisation to manage climate- related risks and opportunities and performance against targets.	Page 75	Compliant

For LR 9.8.6(8) requirements, each section heading has the overview of Ыe Group's alignment to the disclosure recommendations. Ыe Group has made disclosures consistent with the TCFD recommendations.

h

Governance

Describe the Board's oversight of climate related risks and opportunities

Ыe Board has oversight and approval of Ыe Group's ESG strategy, including commitments to reduce the environmental impact and progress toward net zero emission by 2050. Ыe Executive committee supports the Board by overseeing the Group's risk management framework, evaluating the climate related risks and opportunities, and updating the Board over the year as well as the ongoing significance of sustainability to stakeholders and their specific areas of interest.

Changes in FY 2025

ESG has been a talking point for the Board over the past financial year and the Board have been kept abreast of ESG matters.

Next steps and time frames

Ыe Board will continue to engage on ESG and climate change issues, allowing them to manage climate risk. Ыe Group will aim to include more risk and opportunity information into the Board decision-making process on a regular and agreed-upon basis.

Describe management's role in assessing and managing climate-related risks and opportunities

Ыe Audit Committee supports the Board, and reviews the Group's risk management framework and the Group's overall risk management policy. Ыe Audit Committee bears the primary responsibility

of incorporating climate-related concerns into the assessment and direction of strategy, significant action plans and risk management protocols.

Changes in FY 2025

In 2025 the Audit Committee considered climate related risks, within the wider risk policy for the Group.

Next steps and time frames

Ыe Audit Committee and Board will continue to address the climate related risks and opportunities when they occur.

Strategy and Risk Management

Describe the climate-related risks and opportunities the organisation has identified over the short, medium, and long term

Ыe scale of ambition and speed of change required to meet net zero emission targets, along with the changes in weather patterns, present both risks and opportunities to our business in the short, medium and long term (< 1 year, 1- 3 years and >3 years respectively).

Ыe Group has reviewed several high-level scenario analyses on the potential impacts of climate change to help us consider and adapt our strategies and financial planning seen below. Ыis analysis led us to understand that limiting warming to 2°C would primarily expose us to economic and regulatory transition risks, whereas a 4°C warming level would expose us to unprecedented physical risks.

Ыe Group reviewed different risks and opportunities presented in TCFD Disclosures (Tables A1.1 and A1.2) and considered which were the most relevant and material to the Group. More detail on these risks, opportunities and the mitigating and adaptation actions we are taking can be found in the table below.

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Task Force on Climate Related Financial Disclosures

Our significant climate-related risks and opportunities and our strategic response

Risk

Legislation

Group Wide

Short, medium and long term Likelihood: moderate Measurement: GHG emissions

Substitution of existing products and services with lower emissions options Group Wide

Short, medium and long term Likelihood: moderate Measurement: GHG emissions

Increased severity of extreme weather events such as cyclones and floods. Rising Sea levels and rising mean temperatures. Group Wide

Long term Likelihood: moderate

Measurement: GHG emissions

Opportunity

Move to more efficient buildings to help hit climate targets

Group Wide Short term Likelihood: high

Measurement: Energy Costs

Transition to lower carbon economy and requirement for lower emission technology Group Wide

Short term Likelihood: high

Measurement: GHG Emissions

Potential impact

Financial impacts from increased operating costs e.g. insurance and compliance

Lower emission products may be more expensive, which will impact the Group financially. Ыis is relevant to the Group, whose operating expenses include substantial hosting and database costs, which relies heavily on power.

Higher costs from negative impacts on workforce (e.g., health, safety, absenteeism). Increased insurance premiums and potential for reduced availability of insurance on assets in "high-risk" locations

Potential impact

Reduced operating costs by lowering energy bills and reducing office footprint where appropriate

It will lead to an increase in demand for cloud solutions that offer net zero, if the ESG Strategy is correctly implemented for the Group, then customers may move from competitors to a lower carbon alternative.

Response

As governments and regulatory bodies introduce fresh environmental laws and regulations, the Group will remain subject to their influence, striving

to align with the stipulations while pursuing its Net Zero objectives.

Ыrough our Scope 3 emissions work, we will look to transition away from suppliers who are deemed have a bad rating.

Look to engage with staff in high risk areas, specifically

in APAC region, to ensure safety of staff and future proofing of offices.

Discuss potential financial implications of insurance premiums due to extreme weather.

Response

Consider move to an efficient building to help meet targets

Ыe Group will continue to monitor our Scope 1 and

2 emissions compared to our competitors

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Task Force on Climate Related Financial Disclosures

Risk Management

Describe the organisation's processes for identifying and assessing climate- related risks.

A team has been formed to assess climate based risk and will feed in to the risk register.

Ыe analysis performed for the climate related risks has taken into consideration the short, medium and long term impacts and the likelihood of the risks.

Climate Scenarios

Climate scenarios created by the Network for Greening the Financial Systems (NGFS) were reviewed as part of the assessment of potential climate related risks and opportunities that Pulsar Group may be exposed to. While the NFGS scenarios were developed primarily for use by central banks the scenarios are also useful to the broader private sector.

Scenario Rationale

• Meet the TCFD recommendations for considering the different climate-related scenarios, including 2˚C or lower.

• Modelled against a 30-year timeline. Ыis considers the Paris Agreement of a 2050 net zero target.

• Scenarios are modelled against the NGFS Climate Scenarios. Ыe NGFS Scenarios have been developed to provide a common starting point

  for analysing climate risks to the economy and financial system.

• Considers the impact of physical and transition risks.

Orderly <2˚C

Net Zero 2050 achieved global warming is limited to

1.5˚C through stringent climate policies and innovation, reaching global net zero C02 emissions around 2050

Impact:

• High level of transition risk risks compared to other scenarios.

• Physical risks are reduced due to positive action compared to other scenarios

  Disorderly <2˚C

  Net Zero 2050 achieved; but with higher costs due to divergent policies introduced across sectors leading to a quicker phase out of oil use.

  Impact:

• Higher level of transition risk risks compared to other scenarios

• Physical risks are limited compared to other scenarios

  Hot House World >3˚C

  Net Zero 2050 not achieved. Assumes all pledge policies even if not yet implemented and only currently implemented policies are preserved.

  Impact:

• Limited transition risks compared to other Scenarios

• Physical risks are the highest compared to other scenarios

Metrics and Targets

We have metrics and targets that allow us to measure our impact on the environment, demonstrate our commitment and monitor our performance. Ыese are first published in this report and we will report our progress against those targets and our key metrics on an annual basis.

We have a commitment to reduce our impact by achieving net zero for our Scope 2 emissions by 2050.

Alongside this, we have a Scope 3 emissions reduction target of a 37.5% reduction by FY 2034 from an FY 2022 baseline year. Ыis target includes all of our Scope 3 emissions.

Numerous underlying metrics support and complement this goal as part of our broader sustainability ambition, including reducing our energy consumption, recycling and/or reusing our recovered assets and reducing our office waste. Ыese are discussed in more detail on page 69 and in our Strategic Report.

At Pulsar Group we are committed to responsible carbon management and reducing our carbon

footprint throughout the organisation. Ыe figures in the below table were calculated based on Government Greenhouse Gas Protocol conversion factors and in line with acceptable SECR methodology, specifically the GHG Protocol Corporate Standard.

Due to the nature of the organisation, the business does not generate scope 1 (direct emissions from our operational activities) emissions, and so there are only scope 2 (indirect emissions from our purchase and use of gas and electricity) and Scope 3 (other indirect emissions from activities and sources outside of our ownership or control) emissions to report.

Usage data for Scope 2 has been obtained from the respective building management companies in kWh and converted to GJ and CO2e using the aforementioned GHG Protocol conversion factors.

Scope 3 emissions have been calculated using supplier spend data with support from a recognised 3rd party specialising in the calculation of indirect emissions.

		2025			2024
TCFD Framework	Region	kWh	GJ	CO2e (tonnes)	kWh	GJ	CO2e (tonnes)
	EMEA	51,672	186	9	31,848*	115	8
Scope 2	APAC	600,457	2,161	384	715,661	2,576	319
	TOTAL	652,129	2,347	393	747,509	2,691	327
	EMEA			2,260			2,967
Scope 3	APAC			2,836			4,804
	TOTAL			5,096			7,771

*includes estimate from 9th August to 30th November pro rated for the year.

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Audit committee report

The Audit Committee is responsible for ensuring the integrity of the financial statements of the Group and ensuring that the financial performance is properly reviewed and reported.

Its role is to provide oversight and governance over the Group's financial reporting, audit and risk which includes monitoring the integrity of the financial statements (including annual and interim accounts and results announcements), reviewing internal control and risk management systems, reviewing any changes to accounting policies, reviewing and monitoring the extent of the non-audit services undertaken by the external auditors, and advising on the appointment of the external auditors.

Membership and Governance

Ыe Audit Committee is chaired by Sarah Vawda and its other member is Christopher Satterthwaite, who are both Non-Executive Directors. Ыe Chief Executive Officer and Chief Financial Officer are invited to attend all Committee meetings. Ыe Committee's deliberations are reported at the next Board meeting and the minutes of each meeting are made available to all members of the Board. Ыe Board considers that,

in line with the Committee's Terms of Reference, its members have sufficient recent and relevant financial experience and a range of financial and commercial expertise necessary to meet its responsibilities in compliance with the QCA Code. Ыe biographical details of the current Directors, including their skills and experience, are set out on pages 41 and 43.

Ыe external auditor, BDO LLP, attended Committee meetings by invitation where discussions included conclusions in respect of the 2024 audit and planning of the 2025 audit.

Ыe Committee meets at least three times a year at appropriate intervals in the financial reporting and audit cycle and will meet at other times during the year as and when required or when requested by a Committee member or the external auditor.

Ыe Committee continues to fulfil a vital role in the Group's governance framework, providing independent challenge and oversight of the financial reporting and internal control processes, risk management, and the relationship with the external auditor, BDO LLP.

Responsibilities

Ыe Committee's Terms of Reference are available to view on the Group's website. Its primary duties as set out in the Terms of Reference include:

• Monitoring and reviewing the adequacy and effectiveness of the Group's internal financial controls and internal control and risk management systems.

• Overseeing the relationship with the external auditor and assessing their independence and objectivity.

• Reviewing and approving the statements in the annual report concerning internal control, risk management, and the viability statement, including the assessment of principal and emerging risks.

• Reviewing the adequacy of the Group's overall risk assessment and internal control systems, processes and procedures to identify and manage risk, including the capability to identify and manage new and emerging risks.

Summary of activities

Ыe Committee has an extensive agenda of items of business which concentrate on the audit and risk processes within the Group and are dealt with

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77 Environmental, Social and Corporate Governance

Audit committee report

in conjunction with executive management and the external auditor. Ыe Committee has met formally six times in the year for the following discussions:

• Assessed audit strategy memorandum to address key issues of significant risks, key audit matters and other judgements and enhanced risk review;

• Reviewed annual report and financial statements, and recommended their approval to the Board;

• Reviewed the viability statement and going concern status; reviewed the effectiveness of the audit;

• Discussed the Committee performance evaluation report and Terms of Reference;

• Reviewed the budget and recommended its approval to the Board; and

  Subject	Action taken	Conclusion
  External auditor fee	Ыe Committee reviewed the proposal for the FY25 external audit.	Ыe Committee agreed the fee and scope for the FY25 external audit.
  External auditor independence	Potential conflicts of interest with the external auditor are monitored regularly at Committee meetings.	Ыe Committee is satisfied with the independence, objectivity and effectiveness of the external auditor, in full accordance with the Group's non-audit services policy.
  Budget Proposal	Ыe Committee reviewed and challenged management on the budget proposal.	Ыe Committee agreed the budget proposal and recommended it for approval to the Board.
  Terms of reference	Terms of Reference were reviewed and updated.	Revised Terms of Reference were reviewed by the Committee in January 2025 and were subsequently approved by the Board.
  Whistleblowing policy	Ыe Committee maintains a commitment to upholding its Whistleblowing policy by providing confidential channels for employees to speak up about their concerns. Ыe Committee has a standing item on all agendas on Whistleblowing.	Ыe Committee is comfortable that the current policy is operating effectively.

• Reviewed and approved the audit and non-audit fees.

Areas of focus and significant matters considered by the Committee

Subject	Action taken	Conclusion
Financial Statements	Ыe Committee reviewed and challenged the Group's Interim and Annual Report and Accounts and Results' Announcements. Ыe Committee considered the presentation of the Financial Statements and, in particular, whether the Annual Report and Accounts as a whole were fair, balanced and understandable.	Ыe Committee recommended the Interim and Full Year results to the Board for approval.
Going Concern assumption	Ыe Committee evaluated various reports from management that set out the view of the Group's going concern and longer-term viability. Ыese reports detailed the impact of outcomes of stress tests after applying multiple scenarios to determine how the Group can cope with deterioration in liquidity profile or capital position.	Taking into account the assessment by management of stress-testing results and risk appetite, the Committee agreed to recommend the Going Concern and Viability Statement to the Board for approval.
Risk Management	Ыe current framework, systems and policies in place as described on pages 27 to 32.	Ыe risk register was reviewed by the Committee which continued to evolve in order to reflect the ongoing changes in the Group and the macro-environment. More detail is available on pages 27 to 32.

External Auditors

Ыe Committee monitors the relationship with the external auditor, BDO LLP, to ensure that auditor independence and objectivity are maintained.

Auditor independence

Ыe Committee monitors the provision of non-audit services by the external auditor. Ыe Group has a formal policy on the engagement of the External Auditor for non-audit services. Ыe policy states that the auditor shall not undertake any non-audit services for the Group without the approval of the Audit Committee. Potential conflicts of interest with

the external auditor are reviewed regularly by the Audit Committee. Ыe breakdown of fees between audit and non-audit services is provided in Note 5 of the Group's financial statements.

Internal Audit

At present the Group does not have an internal audit function and the Committee believes that management is able to derive assurance as to the adequacy and effectiveness of internal controls and risk management procedures without one. Ыe

Committee reviewed whether there was a need for an internal audit function during the year and concluded that given the size of the Company there was no requirement to have one.

Risk management and internal controls

As described on pages 27 to 32 of the annual report, the Group has established a framework of risk management and internal control systems, policies and procedures. Ыe Audit Committee is responsible for reviewing the risk management and internal control

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