POLICY PURPOSE AND SCOPE

This policy outlines our commitment to identifying and combating modern slavery and human trafficking, ensuring that we conduct our business fairly and ethically. It sets the procedures we have in place to prevent, detect, and respond to modern slavery.

E&E Group is committed to preventing modern slavery in all its forms. This includes human trafficking, forced labour, and any other practices that exploit individuals for labour. We recognise our responsibility to uphold human rights and maintain ethical standards within our operations and supply chains.

This policy applies to all employees, contractors, suppliers, subsidiaries and partners of E&E Group across all locations and levels of E&E Group.

1. DEFINITION

E&E Group considers that modern slavery encompasses:

• Human trafficking
• Forced work, through mental or physical threat
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse
• Being dehumanised, treated as a commodity or being bought or sold as property
• Being physically constrained or to have restriction placed on freedom of movement

2. OUR COMMITMENT

E&E Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. E&E Group understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The group does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in any modern slavery activities. This is checked through our supplier process.

3. EMPLOYEES AND RECRUITMENT

No labour provided to the E&E Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. E&E Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom. Where there is a requirement to work in other countries, the requirements of that country will be adhered to where these standards are equal to or surpass the requirements of the United Kingdom.

The HR department ensure that all employees have the legal right to work in the UK. Background checks are completed through security screening practices to minimise the risk of hiring individuals linked to exploitative practices.

4. SUPPLY CHAINS

E&E Group understand that first-tier suppliers may be intermediary traders and therefore have further contractual relationships with lower-tier suppliers.

5. POTENTIAL EXPOSURE

E&E Group considers its main exposure to the risk of slavery and human trafficking to exist within contractor and sub-contractor, labour only provisions.

In general, E&E Group considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

6. STEPS

E&E Group carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains.

E&E Group has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, E&E Group has taken the following steps to ensure that modern slavery is not taking place:

• annual supplier reviews
• measures are in place to identify and assess the potential risks in supply chains
• take action to embed a zero-tolerance policy towards modern slavery

7. RESPONSIBILITIES

Management: Senior management are responsible for ensuring the implementation and enforcement of this policy across E&E Group.

Employees: All employees are required to familiarise themselves with this policy and report any suspicions or breaches concerning modern slavery.

Human Resources: The HR team will ensure staff are aware of this policy.

Training: The SHEQ team will oversee training

8. TRAINING

E&E Group provides training to staff to effectively implement its stance on modern slavery. This training takes place during the induction process.

9. SLAVERY COMPLIANCE OFFICER

All concerns regarding modern slavery should be addressed, and relevant action taken. Any concerns should be reported to the Quality and Compliance team with regard to E&E Group’s obligations.