Modern Slavery Policy

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Introduction

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty

and dignity for another person’s gain. It is a real problem for millions of people around the world,

including many in developed countries, who are being kept and exploited in various forms of slavery.

Every company is at risk of being involved in this crime through its own operations and its supply

chain.

At Woodstreet Maintenance Ltd, we have a zero-tolerance approach to modern slavery, and, are

fully committed to preventing slavery and human trafficking in our operation and supply chain. We

have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement

sets out the actions that we have taken to understand all potential modern slavery risks related to

our business, and to implement steps to prevent slavery and human trafficking during the financial

year 2024

Our business and supply chains

Brief details of:

Woodstreet Maintenance Ltd

Construction, maintenance

United Kingdom

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually

beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the

supplier’s reputation, respect for the law, compliance with health, safety and environmental

standards, and references.

[We haven’t been made aware of any allegations of human trafficking/slavery activities against any

of our suppliers, but if we were, then we would act immediately against the supplier and report it to

the authorities.]

Risk assessment

In the past year, we conducted a risk assessment of our supply chain by taking into account:

The risk profile of individual countries based on the Global Slavery Index

The business services rendered by the suppliers

The presence of vulnerable demographic groups

A news analysis and the insights of labour and human rights groups

This assessment will determine our response and the risk controls that we implement.

Policies

Woodstreet Maintenance Ltd operates the following policies for identifying and preventing slavery

and human trafficking in our operations:

Whistleblowing Policy – we encourage all employees, customers and suppliers to report any

suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential

helpline to protect the identity of the whistle blowers.

Code of Conduct – our code encourages employees to do the right thing by clearly stating the actions

and behaviour expected of them when representing the business. We strive to maintain the highest

standards of employee conduct and ethical behaviour when operating abroad and managing our

supply chain.

Purchasing Code – we have updated our Purchasing Code and supplier contracts to make explicit

reference to slavery and human trafficking.

Supplier due diligence

Woodstreet Maintenance Ltd conducts due diligence on all new suppliers during on-boarding and on

existing suppliers at regular intervals. This includes:

Assessing risks in the provision of particular services

Auditing the suppliers, and their health and safety standards, labour relations and employee

contracts

Requiring improvements to substandard employment practices

Sanctioning suppliers that fail to improve their performance in line with our requirements

We require all suppliers to attest that:

They don’t use any form of forced, compulsory or slave labour

Their employees work voluntarily and are entitled to leave work

They provide each employee with an employment contract that contains a reasonable notice period

for terminating their employment

They don’t require employees to post a deposit/bond and don’t withhold their salaries for any

reasons

They don’t require employees to surrender their passports or work permits as a condition of

employment

Awareness

Woodstreet Maintenance Ltd has raised awareness of modern slavery issues by putting up posters

across our facilities and sending an email that is focused specifically on modern slavery to all our

staff, which explains:

Our commitment in the fight against modern slavery

Red flags for potential cases of slavery or human trafficking

How employees should report suspicions of modern slavery

Training

In addition to the awareness programme, Woodstreet Maintenance Ltd has rolled out a fresh elearning course to all employees and supplier contacts, which covers:

Various forms of modern slavery in which people can be held and exploited

The size of the problem and the risk to our organisation

How employees can identify the signs of slavery and human trafficking, including unrealistically low

prices

How employees should respond if they suspect slavery or human trafficking

How suppliers can escalate potential slavery or human trafficking issues to the relevant people

within their own organisation

What external help is available for the victims of slavery

What terms and guidance should be provided to suppliers in relation to slavery policies and controls

What steps Woodstreet Maintenance Ltd will take if a supplier fails to implement anti-slavery

policies or controls

An attestation from employees that they will abide by Woodstreet Maintenance Ltd’s anti-slavery

policy

Measuring how we’re performing

Woodstreet Maintenance Ltd has defined a set of key performance indicators and controls to

combat modern slavery and human trafficking in our organisation and supply chain. These include:

How many employees have completed mandatory training?

How many suppliers have filled out our ethics questionnaire?

How many suppliers have rolled out an awareness and training programme that is equivalent to

ours?

How many reports have been made by our employees that indicate their awareness of and

sensitivity to ethical issues?

What are the findings of our cross-functional Human Rights team, which reviews how we are

addressing modern slavery and human trafficking?

This statement covers 1st April 2024 to 31st March 2025 and has been approved by the board of

Woodstreet Maintenance Ltd at the board meeting on 01/04/24

Date: 02.04.2024