Modern Slavery

Declaration
This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps taken by P.P. O’Connor Group Limited for the period April 2024 to March 2025 to prevent modern slavery and human trafficking in its own business operations and supply chains.

Introduction
P.P. O’Connor Group Limited has implemented a Modern Slavery Statement to reflect its commitment to combatting slavery and human trafficking. It further commits to acting with integrity in all its dealings, relationships and supply chain. We strictly prohibit all forms of modern slavery and human trafficking in our operations, bases and supply chain. We have and will continue to be committed to implementing systems and contracts aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains.

It is our supplier’s responsibility to identify and report potential modern slavery cases, and we are committed to supporting them in mitigating and remediating identified cases.

The Board of Director(s) holds ultimate responsibility for modern slavery and expects its senior management to engage with all interested parties to prevent modern slavery within the company.

P.P. O’Connor Group Limited expects that our suppliers will hold their own suppliers to the same high standards.

Modern slavery encompasses slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human Trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited and deprived of their freedom.

Modern slavery is a crime and a violation of fundamental human rights as detailed in the Modern Slavery Act 2015.

Key focus areas
P.P. O’Connor Group Limited takes its responsibilities to combat modern slavery seriously and expects everyone working with us or on our behalf to do the same. The Company demonstrates its commitment by its promotion and adoption of the following measures:

  1. We encourage reporting of potential exploitation internally and within our supply chain so we can investigate, mitigate and support in the resolution of identified cases.
  2. We have a commitment to legal compliance, ethical standards and fundamental human rights as set out by the principles of the ILO/UN Guiding Principles.
  3. We have a commitment to raising awareness of modern slavery issues including how to spot the signs in the business and supply chain.
  4. The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for the Company or under its control. All interested parties are responsible for reporting any modern slavery concerns or issues that they have to senior management. This will be treated with the strictest of confidence.
  5. Workers must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this statement.
  6. We are committed to addressing any issues and prohibit any practices that are known to contribute to the risk of modern slavery. This applies also to any practice that have been notified to the company.
  7. The Company encourages anyone to raise any concerns about modern slavery, using its whistleblowing policy if necessary, and will support anyone who acts in good faith.
  8. The Company’s recruitment policies and procedures support its efforts to combat modern slavery and human trafficking and confirm its right to ask employment and recruitment agencies and other third parties supplying workers to our organisations to confirm their compliance with our Sub-Contract Agreement Terms.
  9. The Company will continue to develop its commitment to combat modern slavery and human trafficking.

Business and operational structure
P.P. O’Connor is an organisation operating within the construction industry, specialising in demolition, civil engineering, bulk earthworks, remediation, aggregate supply and recycling. P.P. O’Connor has a financial year (April 2024-March 2025) annual turnover of £70 million, is not a parent company, and does not have any subsidiaries. We have approx. 300 employees with a dedicated management team and a highly skilled workforce.

We procure Contractors to carry out specialist activities on behalf of P.P. O’Connor, these include but not limited to: Crane Hire, Licensed Asbestos Removal, Scaffolding, Structural Engineers.

The Contractors are UK based and procurement of them is a centralised activity carried out by Head Office following our internal procedures.

Governance structure
The Board of Directors have overall responsibility for ensuring this statement complies with our legal obligations, and that all those under our control comply with its contents.

Our nominated ‘Compliance Team’ comprises of the following: Managing Director, Director Responsible for HSEQ and the Human Resources Manager. They work together to ensure that our commitment to modern slavery is maintained across all operational areas of the Group in accordance with evolving regulatory requirements and to ensure that any breaches or concerns are addressed.

Policies, processes and considerations
POL009 Anti-Corruption and Bribery
POL012 Modern Slavery and Human Trafficking
POL013 Whistleblowing Policy
POL014 Disability Discrimination Policy Statement
POL037 Ethical Policy
These policies are reviewed on an annual basis in accordance with our Quality Management System. Direct employees are given the policies during induction and further access is via the internal Information Hub.

Supply chain
P.P. O’Connor engage with third party Contractors to carry out specialist tasks on our behalf. These include crane hire, scaffolding, licenced asbestos removal, amongst others. We do employ the services of supplied labour where necessary.
The Contractors we use are selected from a list of previously verified (internally) Contractors and are located around the UK. The verification process includes the completion of a pre-qualification questionnaire (PQQ) and the requirement to provide evidence against the questions. Modern Slavery is a requirement of the PQQ and evidence is mandatory.

We acknowledge that the industries P.P. O’Connor operate within are high risk and that the construction industry is the second highest single sector for labour exploitation according to the UK’s Modern Slavery and Exploitation Helpline (2023). The waste and recycling sector is also high risk for exploitation.

Due diligence
All Contractors complete a PQQ prior to working for P.P. O’Connor. An order cannot be placed without this verification from several departments within the business – mainly HSEQ, Commercial and Human Resources. The modern slavery requirements we ask of our suppliers are as follows:

  • Can you demonstrate when procuring materials that they are not sourced using ‘Child Labour’ with a violation to human rights? If yes, please provide details.
  • Please give details of your current procedures and processes to ensure all employees have the right to work in the UK in line with current UK Law – Asylum and Immigration Act 2006.
  • Please confirm (whether or not your organisation is UK based) that you understand the requirements as they apply to your organisation, of The Modern Slavery Act 2015 (The Act) and The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015. Please attach a copy of your Policy Statement or process to ensure compliance.

It is a requirement that before employment commences, prospective employees provide the Company with confirmation of their eligibility to work in the UK by providing the relevant original document or documents detailed on the government website for right to work. Sub-Contract Agreements are signed once checks are completed and the Contractor confirms they are compliant with the Modern Slavery Act and will report any instances of exploitation to us as soon as practically possible.

When Contractors’ employees arrive on site CSCS cards are checked for validity using the card checker app/website.

Reporting, escalation, and remediation
At induction stage (company and site), employees are briefed on the contents of our Modern Slavery Policy and Whistleblowing Policy and how to report any potential exploitation. This is actively encouraged. If a concern is raised through our reporting mechanism and is flagged as indicating potential modern slavery or exploitation, the contents of the report would be escalated to the relevant persons in the business to investigate confidentially. The Modern Slavery and Exploitation Helpline will be called for
help and guidance.

Training
Employees are informed of the P.P. O’Connor Anti-Slavery policy at their induction. We are looking to improve training requirements in the business during the next financial year and have set an objective for this.

Future objectives
Future objectives for the business will be to:

  • Increase awareness throughout the business to maximise identification of any potential instances occurring by enrolling relevant personnel (Directors, Operational, Commercial and HSEQ teams) onto the internal iHasco Modern Slavery training.
  • Relevant staff members (HSEQ, Commercial, HR and relevant Directors) will undergo specialist training, delivered by the anti-slavery charity Unseen. This will include including the signs to spot, the scale of the issue, how to reduce risk during the procurement process, and what to do if a concern is identified.
  • Improve the way an anonymous report can be raised in the business easily and is accessible for all areas of the business. A single QR code to be made and shared across the group enabling simple and easy reporting and to allow investigations to be carried out. The QR code will be accessible to anybody including our supply chain and Contractors.

Approval
This statement was approved by the Board of P.P. O’Connor Group Limited.

Signed by : Peter O’Connor, Chairman (signed copy available on request)


Date: 12th September 2025

Next Review Date: During April 2026