Modern Slavery and Human Trafficking Statement

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (the “Act”) and sets out the steps that the Lagan Specialist Infrastructure Group Limited (LSIGL) has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

DEFINTIONS:

Modern Slavery: When an individual is exploited by others, for personal or commercial gain. Whether tricked, coerced, or forced, they lose their freedom. It includes, but not limited to, human trafficking, forced labour, debt bondage and servitude.

Human Trafficking: Recruitment, transportation, transfer, harbouring or receipt of persons, using threat or use of force or other forms of coercion, abduction, fraud, deception, abuse of power or abuse of a position of vulnerability or giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation

OUR GROUP STRUCTURE

Lagan Specialist Infrastructure Group Limited is part of the Lagan Specialist Contracting Group which is a private family-owned construction and civil engineering business which provide specialist contracting and services solutions throughout the UK, Ireland and overseas.

For the purpose of this policy, , LSIGL includes:

• Lagan Aviation & Infrastructure Limited

• Lagan Airport Maintenance Limited

• Lagan MEICA Limited

• Charles Brand Group Limited

• FK Plant Limited

OUR POLICY ON ANTI-SLAVERY AND HUMAN TRAFFICKING

LSIGL supports the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking. We are a growing, sustainable and ethical business and do not support or engage with any business knowingly involved in such activities. We conduct our business dealings and build relations with integrity. We implement and enforce effective systems and controls to ensure modern slavery modern slavery does not take place within our business or our supply chains. Our goal is to prevent modern slavery and human trafficking in all aspects of our business operations and supply chains. This includes our responsibility to uphold human rights and ensure that our business practices are ethical and transparent. We have a zero-tolerance approach to modern slavery and human trafficking. Our policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our supply chains.

We acknowledge that slavery and human trafficking can occur in many forms. Therefore, throughout this disclosure the terms “slavery and human trafficking” to encompass various forms of coerced labour. We believe that working collaboratively in partnership with our clients, community stakeholders and supply chain enables us to find practical, safer methods of ethical trading free from slavery and human trafficking.

We have embedded modern slavery and human trafficking risk and management into how we do business. In addition to our annual statement, we have several policies to ensure that we are conducting business in an ethical and transparent manner:

• Anti-Bribery and Corruption Policy

• Recruitment and Selection Policy

• Whistleblowing Policy

• Supply Chain Code of Conduct

Our policies are made available to all employees through our common data environment which is where information is shared and communicated. These policies are made available to all our supply chain partners through the contract management process.

OUR ANTI-SLAVERY AND HUMAN TRAFFICKING ASSURANCE PROCESS

As part of an initiative to identify and mitigate risk in respect of slavery and human trafficking, we have:

  • Developed and agreed our Anti-Slavery and Human Trafficking Policy and Management Standards.

  • Reviewed contracts with subcontractors to confirm their compliance with the Modern Slavery Act. Suppliers and subcontractors are required to notify us as soon as they become aware of any instance of modern slavery or human trafficking taking place in their business or supply chain.

  • Reviewed our recruitment processes to ensure they continue to be transparent and thorough. We have robust procedures in place for vetting new employees and ensuring we can accurately confirm their identities and their ‘right to work’.

  • Robust security checks which includes a ‘right to work’ check conducted by our security teams on projects to ensure that all subcontractors and agency persons are legally permitted to work in the jurisdiction where we are working.

  • Ensure that all staff have a written contract of employment.

  • Developed and rolled out a subcontractor code of conduct to ensure that our supply chain partners are aware of their role in preventing and reporting modern slavery.

To further improve our assurance process, we will:

  • Conduct a modern slavery risk assessment across all business units in LSIGL

  • Enrol our staff on modern slavery training based on their roles and responsibilities

  • Increase awareness of modern slavery within construction across our supply chain through training and communications across our sites

  • Conduct checks on policies, human resource and security processes and supply chain management to ensure compliance

RISK

Through our risk assessment process, we map out our supply Chain and identify parts of the business or supply chain where there is a medium to high risk of modern slavery and identify remediation actions to lower or minimise the risk. When conducting a risk assessment, we:

  • Identify which services and products are most prone to modern slavery, what regions they are typically home to and the types of workers that are most at risk

  • Examine our operations to identify which parts of our supply chain are most vulnerable

  • Assess the risk levels of our supply chain partners

  • Implement a programme of checks and controls to mitigate any identified risks

We are conducting a supply chain mapping exercise to better under the risk of modern slavery within our supply chains. To mitigate the risk associated with modern slavery, we will engage with key stakeholders and work with our supply chain partner to continuously improve labour practices across our value chain.

DUE DILIGENCE, MONITORING AND REPORTING

As part of our due diligence process, we request copies of all relevant supply chain’s Modern Slavery Statement as part of our supply chain vetting procedure. We adopt a risk-based approach to auditing our supply chain. Where any of our supply chain partners falling into high-risk categories, an audit will be conducted with them. This includes, but not limited to, enquiring into their operations, how their labour and materials are sourced, salaries of their works and prices paid to their suppliers further down the supply chain. More checks are carrier out on suppliers or part of the business that most the most risk.

On our project sites, inspections on our hiring and security clearance processes. This includes checks on our supply chain right to works and the conditions of their visa, were applicable. Findings from our due diligence process will feed back into our modern slavery risk assessment for the business.

Modern slavery complaints and concerns are managed through our Whistleblowing policy and reporting procedures. Worker-level incident reporting is communicated to our workforce through our inductions, toolbox talks and communications across sites. All complaints and concerns are managed locally, as far as possible, and escalated as necessary.

To measure the effectiveness of our due diligence efforts, we have included Modern Slavery KPIs as part of our Sustainability KPIs and are monitored every quarterly by our Board of Directors. The effective of our mechanisms are monitored through our assurance process.

TRAINING

To ensure that employees understand the risks of modern slavery and human trafficking in our supply chains and in our business, we provide training for all staff as part of their onboarding, and annually after to inform them of appropriate actions to they if they suspect a case of slavery or human trafficking. This training includes:

  • Introduction to modern slavery

  • Human Trafficking

  • Labour exploitation

  • Hidden Slavery

  • Legislation

  • Warning signs

  • Good business practices

To ensure a level of understanding, all employees are required to score a minimum of 80%. Through our supply chain code of conduct, we have outlined our expectations of our supply chain with regards to modern slavery. Our supply chain partners are required to acknowledge the compliance with our code of conduct as part of their contractual requirements with us. As part of our assurance improvement, we will roll our modern slavery training to our supply chain partners and continue to engage with them on project-level.

REMEDIATION

In addition to having processes in place to identify and stop modern slavery and to prevent future incidents, anyone harmed in this way as a result of our business activities would be remediated. Modern slavery victims can raise issues and suggestions and seek redress, not only through our Whistleblowing Policy but also through our grievance mechanisms.

Remediation may be through restoring individuals or groups that have been harmed to the situation they would have been in had the negative impact not occurred. If this is not possible, using compensation, reparation or other forms of remedy will be used to redress the harm caused.

We understand that while we do not have a responsibility to remediate all adverse impacts which are directly or indirectly linked to us, we will use our leverage to encourage our supply chain partners to provide effective remediation for any adverse impact they have contributed to. As part of our remediation process, we will also take a forward-looking approach to seek to mitigate the risk of such impacts continuing or recurring.

DEVELOPING FOR THE FUTURE

As our approach to slavery and human trafficking develops, we will continue to assess the effectiveness of our processes and improve on them, as required.

This statement has been reviewed by our Board of Directors and is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for the Group of companies for the financial year ending 31 March 2025.

Steve Turner

Managing Director