SECTORS & SERVICES PROJECTS CAREERS COMPANY NEWS & MEDIA CONTACT modern slavery statement This statement is made in accordance with the Modern Slavery Act 2015 and constitutes Keltbray’s modern slavery and human trafficking statement for the financial year ending 31 October 2020. Keltbray Group (Holdings) Limited (referred to as Keltbray Group herein), incorporates organisations that make up the Keltbray Group of companies. These organisations are listed at the end of this statement. Keltbray Group is a UK leading specialist engineering and construction business, which provides engineering, construction, demolition, decommissioning, remediation, environmental services, reinforced concrete structures, rail and power distribution and transmission solutions to public and private sector clients. In the main these services are provided on a self-delivery basis. The Group is a key player in developing and maintaining Britain’s built environment and infrastructure, and operates in highly regulated environments. We have implemented policies and procedures to ensure fair and ethical treatment, these include: Equal opportunities and anti-discrimination Training and development Health, safety and wellbeing Fair pay Whistle-blowing Keltbray Group have signed up to the Gangmasters & Labour Abuse Authority construction protocol and we are signatories of this. It is aimed at eradicating slavery and labour exploitation in the construction industry. The construction protocol commits signatories to: Supply Chain Our external supply chain is predominantly made up of organisations utilised across our Built Environment and Infrastructure divisions. We directly contract these organisations to complete work on our behalf or supply materials or labour. The Keltbray Group due diligence process for suppliers incorporates a review of the controls undertaken by the supplier. All organisations that the company deals with are required to confirm that both they and their supply chain are not knowingly involved in slavery and human trafficking. Such a declaration is required by all companies in order to be added to the company’s preferred supplier list. Risk Where we have most control, in respect of modern slavery and human trafficking, is in recruitment of direct employees. We have procedures in place to ensure that recruitment is completed in line with regulatory requirements and our people have access to rights and appropriate conditions. We view this area as low risk. The highest risk to Keltbray Group is through our temporary staff whom are recruited via recruitment agencies. Our recruitment process conforms to regulatory requirements and the fair and ethical treatment of temporary employees. In 2019, we enhanced our process for reviewing recruitment agencies by auditing them across a range of topics, including; modern slavery, business ethics, discrimination and bullying, recruitment practice, health and safety, payroll and competence. We continue to periodically audit our roster of recruitment agencies as part of a continuous improvement process and feedback is provided to the recruitment agencies to assist them in improving their systems and processes. In 2020, we acknowledged that further work was required with our wider supply chain as part of our approach to risk management and mitigation to confirm modern slavery requirements are in place. As a result of this, we have designed and implemented a new pre-qualification questionnaire and onboarding process for agencies that require the suppliers to produce documentation to confirm that they are compliant with requirements for modern slavery and payment of wages. This information is reviewed externally by our insurers who confirm that all of the necessary standards are met for supply. An agency cannot be an approved supplier without providing this documentation and subsequently this reduces the risk and we can confirm that we have found no signs of modern slavery in our supply chain. In 2020, we identified that our whistleblowing policy warranted improvement. As a result of this, we have updated the policy to make it robust and consistent with Keltbray’s open and supportive culture. Training In 2019, we introduced the training modules for modern slavery, corporate social responsibility, and fairness and inclusion. The modules were made available for voluntary completion as part of the Keltbray Learning and Development package. In 2020, further enhancements were made to the modern slavery training, including guidance on ‘right to work’ checks. In early 2021, we launched a digital learning platform that is accessible to all Keltbray people that includes learning in Modern Slavery and Equality, Diversity and Inclusion. These will be mandated at milestones throughout the year. Vince Corrigan Group Chief Operating Officer Date: April 2021 Annex Subsidiary companies of Keltbray Group (Holdings) Limited meeting the criteria to require the preparation of an annual slavery and human trafficking statement, in accordance with the Modern Slavery Act 2015, that are included within the scope of this statement: Keltbray Limited Keltbray Aspire Limited Keltbray Group Limited Keltbray Plant Limited Keltbray Structures Limited