SHAWBROOK GROUP PLC

Policies described

Freedom of workers to terminate employment Freedom of movement 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

Training described

Other

Worker engagement and working conditions

Businesses in your industry or sector

Social audits

Audit conducted by your staff

Grievance mechanisms

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

Demonstrated progress

In 2024 there was no reported instances of modern slavery within the Group or its Supplier Relationships. A further assurance review will take place in early 2025 to test for evidence of the extent to which modern slavery risks have been embedded into policies and processes. The Group will continue to review and monitor its approach to modern slavery amongst our colleagues and suppliers on a regular basis.

Reported risks and mitigations

• Risk: Supply chains extending to oversea jurisdictions that have a higher risk of modern slavery. Due diligence checks are carried out on suppliers including screening and contractual obligations.
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Group: Women Migrants Refugees Other vulnerable groups
• Location: United Kingdom
• Mitigation: Suppliers are predominantly UK based, however there is a risk that Modern Slavery could occur further down the supply chain. We do not have any current concerns. To mitigate this risk we conduct: Supplier Assessments: We conduct assessments of our suppliers above £5,000 to ensure they adhere to MS Regulation. We also conduct Risk Assessments and Assurance activity where necessary.
• Risk: Employees Due diligence checks carried out on employees at the point of onboarding and well-being checks conducted throughout period of employment.
• Area: Within your own operations
• Group: Other vulnerable groups
• Mitigation: Right to work/Reside checks are conducted at on boarding, screening of employees and well-being checks are made throughout employment.
• Risk: Outsourced Service Suppliers Oversight and monitoring carried out on third party suppliers and whistle blowing framework in place to ensure any conduct issues can be escalated.
• Tier: Tier 1 suppliers
• Location: United Kingdom India Poland
• Mitigation: Contractual obligations, screening, policies and site visits where appropriate. We also have a whistle-blowing framework in place enabling conduct issues to be escalated.