NEILCOTT DEVELOPMENTS LIMITED

Policies described

Freedom of workers to terminate employment Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents Provides access to remedy, compensation and justice for victims of modern slavery

Training described

Your whole organisation

Worker engagement and working conditions

Your suppliers Workers within your organisation Workers within your supply chain Law enforcement, such as police, GLAA and other local labour market inspectorates

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app

Other monitoring

We monitor conditions through inductions, toolbox talks, supplier checks, enhanced due diligence, worker verification, high-risk registers and project-specific Modern Slavery Management Plans.

Demonstrated progress

Over the next 12 months, we will measure progress through project-specific Modern Slavery Management Plans, periodic reviews of labour providers and higher-risk suppliers, improved evidence of lower-tier supply chain due diligence, increased training and refresher briefings, and reviews of multilingual and anonymous reporting routes. Health and safety inspections will check welfare, inductions and site information, with findings and actions reported to senior management.

Reported risks and mitigations

• Risk: Temporary construction workers being engaged via supply chain
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers
• Group: Migrants Refugees
• Location: United Kingdom
• Mitigation: We assess labour providers and subcontractors through pre-qualification and enhanced due diligence. Identity, right-to-work and employment checks are required, alongside site inductions, worker welfare monitoring, confidential reporting routes and regular supply chain reviews. Project-specific Modern Slavery Management Plans identify vulnerable workers and set appropriate controls.
• Risk: Workers producing polysilicon for photovoltaic panels in Xinjiang, China, where there is a heightened risk of forced labour.
• Tier: Tier 3 suppliers and below
• Group: Other vulnerable groups
• Location: China
• Mitigation: We assess PV panel suppliers through enhanced due diligence, requiring evidence on product origin, polysilicon sourcing and supply chain traceability. Suppliers linked to higher-risk regions are subject to further review and recorded on our Modern Slavery High-Risk Supplier Register. Where sufficient assurance cannot be provided, we seek alternative products or suppliers and continue to monitor emerging risks.