Glenevin Construction Ltd prohibits the use of modern slavery and human trafficking in our operations and supply chain. We are committed to implementing systems and controls focussed on ensuring that modern slavery and human-trafficking is not accepted within our organisation or in any of our supply chains. We expect our suppliers to take responsibility for ensuring that their suppliers meet the same standards.

This policy applies to all persons working directly or indirectly for the Company in any capacity, including employees at all levels, agency workers, volunteers, agents, contractors & suppliers.

Modern Slavery – Company Commitments

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. This policy summarises our Code of Conduct with regard to combatting modern slavery. Compliance is mandatory.

The Modern Slavery Act 2015 is an Act of the Parliament of the United Kingdom. It is designed to tackle slavery in the UK and consolidates previous offences relating to trafficking and slavery. The company will ensure that they adhere to all legal requirements in this regard and take all reasonable steps to provide a work environment in which all employees are treated with respect and dignity.

The Company expects everyone working with us or on our behalf to uphold the following measures to safeguard against modern slavery:

• We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.

• The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of each individual working for the Company or on behalf of the Company. Workers must not engage in, facilitate, or fail to report any activity that might lead to, or indicate, a breach of this policy.

• We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.

• We take a risk-based approach to our contracting processes and keep them under review. We may, after assessing the merits, write to our suppliers asking them to confirm their compliance with our Code of Conduct.

• We may, after assessing the merits, require our employment and recruitment agencies and any other third-party supplying workers to our organisation to confirm their compliance with our Code of Conduct.

• We may, after assessing the merits, require any suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to our Code of Conduct.

• As part of our ongoing activities we will consider whether circumstances warrant that we carry out audits of suppliers to assess their compliance with our Code of Conduct.

• If we find any individual(s) or organisation(s) working for us or on our behalf have breached this policy we will take appropriate action in a prompt manner including allowing remediation of such breaches, disciplinary action and/or termination of the relationship(s).

Employees, suppliers and third parties should urgently report suspected modern slavery acts or practices to company management.

This statement was approved by the Glenevin Managing Director and will be reviewed 1st February 2024.