Modern Slavery & Human Trafficking Statement

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps taken by EHL Group to prevent modern slavery and human trafficking in our business operations and supply chains.

EHL Group is registered in England and Wales under company number 14905095, with its registered office at The Oak Centre, Aycliffe Business Park, County Durham, DL5 6AU.

EHL Group is a commercial HVAC, mechanical and electrical engineering, building services and construction contractor established in 1993. We deliver services across the United Kingdom to clients in the commercial, industrial, healthcare, education, hospitality and public sectors.

We are committed to conducting our business with integrity and to ensuring that modern slavery and human trafficking have no place in any part of our operations or supply chain.

EHL Group provides engineering, construction, maintenance and facilities management services. Our operations involve a directly employed workforce of skilled engineers, tradespeople and support staff based in the North East of England and deployed to client sites across the UK.

Our supply chain comprises manufacturers and distributors of mechanical, electrical and building materials, specialist sub-contractors engaged for defined elements of project delivery, and providers of professional and business support services.

We operate a number of policies relevant to our commitment to preventing modern slavery:

• Recruitment and employment — all employees are recruited through lawful and transparent processes. We verify the identity and right to work of every individual before employment commences. We do not use gangmasters, labour agencies or any form of forced, bonded or compulsory labour.
• Whistleblowing — we maintain a confidential reporting mechanism through which employees, sub-contractors and other stakeholders can raise concerns about suspected modern slavery or any other unethical conduct without fear of retaliation.
• Supply chain management — we expect all suppliers and sub-contractors to share our commitment to preventing modern slavery. Our standard procurement terms include provisions requiring compliance with the Modern Slavery Act 2015.
• Code of conduct — our employees are expected to act with integrity and to report any concerns about unethical practices in our business or supply chain.

To identify and mitigate the risk of modern slavery, we undertake the following measures:

• We assess the modern slavery risk profile of our supply chain, taking into account the nature of the services provided, the geographic location of suppliers and the labour practices common to our industry.
• We require key suppliers and sub-contractors to confirm their compliance with the Modern Slavery Act 2015 and to provide evidence of their own policies and procedures where requested.
• We conduct pre-qualification assessments of new sub-contractors, including checks on employment practices, health and safety compliance and financial standing.
• We monitor our supply chain for indicators of modern slavery, including unusual working patterns, evidence of debt bondage, restricted freedom of movement or withholding of identity documents.

We consider the following areas to present the highest potential risk within our sector:

• Labour-intensive construction activities where sub-contracted labour is used, particularly in groundworks, demolition, cleaning and site clearance.
• Supply chains involving materials manufactured or processed in jurisdictions with weaker labour protections.

We mitigate these risks by maintaining a predominantly directly employed workforce, limiting the use of sub-contracted labour to specialist activities, and conducting appropriate due diligence on all sub-contractors engaged.

Our management team is aware of the requirements of the Modern Slavery Act 2015 and the indicators of modern slavery and human trafficking.

We provide guidance to employees involved in recruitment and supply chain management on identifying and reporting potential signs of modern slavery.

We measure the effectiveness of our approach through:

• The number of concerns raised through our reporting mechanisms.
• The completion of due diligence checks on new and existing suppliers and sub-contractors.
• The proportion of our workforce that is directly employed versus sub-contracted.
• Regular review of our policies and procedures to ensure they remain appropriate and effective.

This statement has been approved by the directors of EHL Group and will be reviewed and updated annually.