GEOFFREY ROBINSON 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 Your front line staff Human resources Executive-level staff Procurement staff Your suppliers

Worker engagement and working conditions

Your suppliers Trade unions or worker representative groups Professional auditors Workers within your organisation Workers within your supply chain Businesses in your industry or sector

Social audits

Audit conducted by your staff Third party audit arranged by your organisation Third party audit arranged by your supplier Announced audit

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app Through trade unions or other worker representative groups

Other monitoring

Working conditions were monitored through site supervision, welfare inspections, supplier reviews, project audits, labour compliance checks, whistleblowing channels and corrective action reviews.

Actions addressing ILO indicators

Change in policy Change in training Referring potential victims to government services Supporting investigations by relevant authorities

Demonstrated progress

Geoffrey Robinson Ltd measures progress through annual review of key performance indicators, including supplier due diligence completion, labour provider compliance, right-to-work verification, workforce training completion, audit activity, corrective action closure and incident reporting. During 2025, all KPI targets were achieved. The Company has also established improvement objectives and a 2026-2027 action plan focused on enhanced training, governance, supplier engagement and reporting.

Reported risks and mitigations

• Risk: Use of subcontracted, labour-only and temporary labour may increase the risk of worker exploitation, poor employment practices and reduced visibility of labour conditions.
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Group: Migrants Refugees Other vulnerable groups
• Location: United Kingdom
• Mitigation: We mitigate this risk through supplier approval and due diligence processes, right-to-work verification, labour provider assessments, site supervision, workforce welfare checks, project audits, whistleblowing arrangements and enhanced monitoring of higher-risk suppliers. Suppliers and subcontractors are subject to ongoing performance review, with concerns escalated through established management and corrective action processes where required.
• Risk: Complex supply chains and lower-tier subcontracting can reduce transparency and increase the risk of modern slavery occurring without detection.
• Group: Migrants Other vulnerable groups
• Mitigation: We address this risk through supplier due diligence, approval and onboarding processes, risk-based supplier assessments, ongoing performance monitoring, project audits, compliance reviews and enhanced checks for higher-risk suppliers. Supply chain risks are reviewed through procurement and project delivery processes, with corrective actions, additional monitoring and management review implemented where concerns or weaknesses are identified.
• Risk: Procurement of imported construction products and services may present increased risks where labour standards and worker protections are less visible.
• Location: China United Kingdom India Vietnam
• Mitigation: We seek to mitigate this risk through supplier approval, screening, compliance reviews, assessment of labour practices, ongoing supplier monitoring and challenging unverified supply chains, unusual sourcing arrangements and supplier substitutions.