EAST REGEN 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

Worker engagement and working conditions

Your suppliers Professional auditors Workers within your organisation Workers within your supply chain Law enforcement, such as police, GLAA and other local labour market inspectorates Businesses in your industry or sector

Social audits

Audit conducted by your staff Audit conducted by your supplier’s staff Unannounced 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

Monitored working conditions through supplier accreditation, compliance checks, contractual anti-slavery clauses. Implemented Source-to-Pay system to improve supplier visibility.

Demonstrated progress

Our statement demonstrates progress through defined KPIs, including safeguarding referrals by type, staff training completion rates, and supplier compliance checks. We track these annually and report to Executive Group and the Board. Looking ahead, we have set goals to expand supply chain risk assessments beyond tier 1, introduce spot-check audits of recruitment agencies, and increase site visits to high-risk suppliers.

Reported risks and mitigations

• Risk: Exploitation of vulnerable residents, particularly through cuckooing and county lines activity identified via safeguarding referrals
• Area: Within your own operations
• Group: Women
• Mitigation: We addressed this risk through our safeguarding framework, including mandatory staff training, tenancy verification audits, use of vulnerability flags to identify residents at heightened risk. We monitored safeguarding referrals for indicators of modern slavery, including cuckooing & county lines exploitation, and ran targeted awareness campaigns in affected communities. We will continue to strengthen safeguarding measures, expand staff training, and increase community awareness.
• Risk: Labour exploitation risks within our construction supply chains, especially among subcontractors
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers
• Group: Migrants Refugees
• Mitigation: Required all contractors above procurement thresholds to hold Constructionline Gold membership, ensuring compliance with the Common Assessment Standard, including checks on ethical employment and anti-slavery practices. Updated contract templates mandate anti-slavery clauses & Living Wage commitments, with suppliers required to verify subcontractors’ practices. We are rolling out a new Source-to-Pay system to increase transparency, enable real-time monitoring, and improve contract oversight.
• Risk: Risks associated with recruitment agencies supplying temporary staff, where we are strengthening oversight of pre-employment and right-to-work checks.
• Tier: Tier 1 suppliers
• Mitigation: We maintained direct employment practices that comply with the Living Wage Foundation accreditation and provided clear policies and whistleblowing channels for staff to raise concerns. For agency-supplied staff, we strengthened pre-employment and right-to-work compliance through supplier requirements and are developing spot-check audits of recruitment agencies. Looking ahead, we plan to formalise these audits, embed stronger oversight into procurement processes.