OCU UTILITY SERVICES 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 Professional auditors Workers within your organisation Businesses in your industry or sector

Social audits

Third party audit arranged by your supplier

Grievance mechanisms

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

Other monitoring

Monitored working conditions through supplier due diligence, site-level oversight, workforce engagement, induction and awareness programmes, and confidential Speak Up reporting channels.

Demonstrated progress

OCU assesses the effectiveness of its modern slavery programme through supplier risk assessments, due diligence activity, audit outcomes, training completion rates and Speak Up reporting mechanisms. During the reporting period, we strengthened our risk assessment framework, supplier oversight processes and effectiveness monitoring. Future priorities include expanded workforce awareness and the continued development of measurable KPIs to demonstrate progress over time.

Reported risks and mitigations

• Risk: 1. Labour Providers & Temporary Workers Use of labour-only and subcontracted workers across the UK, Australia and New Zealand, where workers may be more vulnerable to exploitation.
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers
• Group: Migrants Refugees
• Location: Australia United Kingdom New Zealand
• Mitigation: We will continue to apply and enhance risk-based due diligence to labour providers and subcontractors, including supplier onboarding assessments, workforce verification processes, contractual requirements, ongoing reviews and Speak Up reporting mechanisms. Awareness training, site inductions and toolbox talks help employees and workers identify and escalate concerns.
• Risk: 2. Complex Supply Chains Goods and services sourced through multi-tier supply chains, particularly in higher-risk sectors and jurisdictions with reduced labour transparency.
• Area: Within your own operations
• Location: Australia Canada China India Italy South Korea Poland
• Mitigation: We use supplier risk profiling, dashboard reporting and supply chain heat-mapping to identify higher-risk suppliers, sectors and jurisdictions. Enhanced due diligence, supplier reviews, contractual controls and ongoing monitoring help improve transparency and strengthen oversight across our supply chains.
• Risk: 3. Migrant & Vulnerable Workers Potential exploitation risks affecting migrant and vulnerable workers involved in construction, utilities and infrastructure activities across Group operations
• Tier: Tier 2 suppliers
• Location: Australia United Kingdom India New Zealand
• Mitigation: We seek to protect vulnerable workers through robust recruitment and onboarding processes, right-to-work verification, awareness training, site-based engagement and confidential Speak Up arrangements. Our controls are designed to identify indicators of exploitation and ensure concerns are escalated and addressed appropriately.