Modern Slavery Policy

Slavery & Human Trafficking Statement Policy

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st October 2022. It covers all Contego Environmental Business and its supply chain. Our anti-slavery policy reflects our aim to act transparently, respectfully and with integrity in all our business relationships. We do not tolerate slavery or human trafficking in any part of our business and are committed to ensuring that it does not take place in our supply chains. We implement and enforce effective systems and controls to mitigate this risk.

Our Supply Chains

We have reviewed our purchases to understand the nature of our suppliers. These include product supply and subcontractors who provide a range of goods and services to help us deliver our business aims and objectives. We have in place systems to mitigate the risk of slavery and human trafficking occurring in our supply chains, allowing us to assess, identify, address and monitor risk areas. We assess the risk of slavery or human trafficking occurring in our supply chains and apply enhanced checks should higher-risk areas be identified. We actively try to use Contego employees for works to ensure compliance with this policy.

Existing Supply Chain

As part of our risk management process, we asked suppliers and sub-contractors to carry out a risk assessments to consider any existing or future arrangements with third parties. This included identification of:

• All businesses they use to provide staff or services, where there is a heightened risk of poor practice, particularly where they employ non-UK nationals or in light of the services the staff are asked to provide;

• Suppliers whose work involves a high level of physical labour; and

• Relationships involving suppliers operating outside the UK, in countries where controls on employment practices may be weaker.

We assessed the responses and identified risk areas so that we could review those relationships in more detail. This process is checked on a yearly basis.

Future Suppliers

We will carry out risk assessments for new suppliers to consider the likelihood of maltreatment of staff or other unsatisfactory factors. This may mean that we decide not to work with them or seek further information, or assurances, before proceeding. For new suppliers where a higher risk is identified:

• If the supplier is required to comply with the Modern Slavery Act 2015, we will review their own published policies on modern slavery.

• For other suppliers, we will seek declarations that they meet appropriate requirements and may ask them to give information on their working practices.

• We will apply appropriate vetting procedures, based on the level of risk identified, to ensure we are comfortable that any risks involving slavery can be identified and addressed promptly.

Supplier Adherence To Our Policy

To ensure all those in our supply chain and contractors comply with our policy, we have in place a supply chain compliance programme. This consists of contractual warranties in our agreements with suppliers, site visits (where deemed appropriate and practically possible) and regular audits to check compliance with our policies and procedures. To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide updates to our staff via our internal newsletters/briefings and by providing both written and oral reminders of good practice.

This statement covers all Contego Environmental Business.