HILL & SMITH INFRASTRUCTURE LIMITED

Policies described

Freedom of workers to terminate employment Prohibits any threat of violence, harassment and intimidation Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents

Training described

Your whole organisation Your front line staff Human resources Executive-level staff Procurement staff

Worker engagement and working conditions

Your suppliers Trade unions or worker representative groups Workers within your organisation

Social audits

Audit conducted by your staff

Grievance mechanisms

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

Other monitoring

Internal Audit, HR, site visits and meeting with employees without management present

Demonstrated progress

We don't employ KPIs, but indicate the areas of risk we have reviewed during the year in question and those we intend to review in the following year.

Reported risks and mitigations

• Risk: The Group has a presence in India, which the Global Slavery Index identifies as having a higher modern slavery prevalence rate.
• Area: Within your supply chains
• Tier: Don't know
• Group: Refugees Children
• Location: India
• Mitigation: Our Indian subsidiary mitigates this risk by holding necessary state and central licences and permits required to operate a manufacturing facility. It is audited internally, and by local authorities to ensure that the facility meets the requisite standards to continue to operate. All employees have identity and age checks undertaken prior to commencing employment. The terms of employment for our Indian employees grant rights to cease employment at will, subject to contractual notice period.
• Risk: Hill & Smith operates in the construction sector which is consistently identified as a high‑risk for forced labour.
• Group: Migrants
• Location: United Kingdom United States
• Mitigation: H&S mitigates sector exposure through a robust, multi layered governance and due diligence framework that is applied consistently across its operations. Core safeguards include a stringent Group Supply Chain Policy, which mandates supplier due diligence, annual performance reviews, and the requirement for all key suppliers to complete Compliance Certificates confirming adherence to anti slavery and human rights standards.
• Risk: A small number of subsidiaries source componentry and raw materials from higher risk jurisdictions. Mining and mineral extraction are consistently flagged by the ILO and GSI as high risk.
• Group: Migrants Children
• Location: China India
• Mitigation: We monitor the countries that provide us with these types of materials and compare them with the Global Slavery Index. Supplier Compliance Certificates provide annual assurance from key suppliers and embed Code of Conduct and Hill & Smith policy mandates reporting of breaches and lowers residual supply chain risk. It is recognised that greater transparency throughout the supply chain will help reduce modern slavery risk.