Modern Slavery Statement - VVB Engineering

Introduction

This statement sets out the VVB Group’s and its subsidiary companies’ (including VVB Engineering (UK)Ltd) actions to understand and address potential modern slavery and human trafficking risks related to its business, in accordance with section 54 of the Modern Slavery Act 2015 and relevant UK statutory guidance. It details the steps put in place to help ensure that modern slavery and human trafficking do not take place within the Company’s own operations or its supply chains.

Our Company

The vision of VVB Group (including VVB Engineering (UK) Ltd.) is to deliver sustainable Mechanical, Electrical, Fire and Telecommunication engineering solutions for our clients, our people, and our environment. We are making continual efforts to understand, raise awareness and engage with our employees and supply chain around the risks of modern slavery.

Modern slavery is a crime and a violation of fundamental human rights and takes various forms; slavery, servitude, forced and compulsory labour and human trafficking, all of which deprive a person’s liberty by another to exploit them for personal or commercial gain.

As part of the Engineering and Construction Sector, VVB recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The Company is committed to responsible operations, particularly regarding human rights issues and have a zero-tolerance approach to human trafficking and other forms of slavery within our operations and throughout our supply chains.

Our Supply Chain

At VVB, maintaining a high-quality supply chain is key to ensuring modern slavery and human trafficking do not take place. Our approach to supplier governance goes through two assessment routes:

Internally – via a subcontractor questionnaire (PQQ) through A-Site
Externally – through the Achilles accreditation scheme (Building Confidence or UVDB) and Constructionline (silver) for Subcontractors

Through this, we assess suppliers against an array of standards, including modern slavery and human trafficking, ensuring that our business and supply chains always act ethically and with integrity.

Our supply chain due diligence includes proportionate checks during supplier and subcontractor onboarding, including review of supplier responses to modern slavery and labour standards questions, confirmation of relevant accreditations where applicable, right to work and labour provider controls where labour is supplied, and review of contractual expectations relating to ethical labour practices. Where higher-risk services are identified, additional checks may be requested before approval or continued engagement.

Relevant Policies

Unethical labour practices including modern slavery and human trafficking are often hidden and the signscan be difficult to spot. VVB have several policies designed to manage and mitigate against modern slavery and human trafficking. These policies are continually assessed for responsible business practices to maintain and control governance to ensure modern slavery and human trafficking are not taking place in our business or across our supply chain. As a result of this, we ensure our policies and procedures are robust so that our operations meet our standards of practice.

The following relevant policies support our zero-tolerance approach to modern slavery and human trafficking:

Whistleblowing Policy / SpeakUp reporting route – VVB-POL-HR-011
Responsible Procurement Policy – VVB-POL-HSE-003
Sustainability Policy – VVB-POL- HSE-004
Recruitment – VVB-POL-HR-013
Modern Slavery Statement – VVB-POL-HSE-008
Supplier and subcontractor onboarding procedures, labour agency approval processes, right to work checks and site-based reporting procedures also support the identification, prevention and escalation of modern slavery concerns.

Our approach to assessing and managing modern slavery and human trafficking risk

Modern slavery and human trafficking awareness is increasingly incorporated into VVB operations through the following actions:

VVB assesses modern slavery risk on a proportionate basis, taking into account the nature of the work undertaken, the use of subcontractors and labour agencies, site-based working arrangements, geographic location, labour intensity, contract value, and any previous concerns or indicators identified through audits, reporting routes or supplier reviews. Higher-risk areas may include construction site labour, subcontracted services, temporary or agency labour, and suppliers operating in sectors where exploitation indicators are more prevalent.

Where a modern slavery concern is raised or identified, VVB will take prompt and appropriate action. This may include escalating the concern through the relevant reporting route, assessing any immediate risk to the individual or workers affected, preserving confidentiality where appropriate, investigating the concern, engaging with the supplier or subcontractor, requiring corrective action, and reviewing whether the supplier relationship should continue. VVB will seek to take a victim-centred approach and avoid actions that could increase risk or harm to affected individuals.

If our workers have any concerns or suspect any incidents of unfair treatment either within our business or supply chain, they are empowered and expected to spot the signs and report concerns as identified in our Whistleblowing Policy or through our ‘SpeakUp’ function on Notify. This provides a confidential mechanism for our employees and others working within our supply chain to report suspected modern slavery practices.
Regular Toolbox Talks are delivered on spotting the signs of Modern Slavery and how to report any concerns. Our workers are encouraged to make full use of available resources for best practice from the Supply Chain Sustainability School.
All recruitment/labour agencies are verified through a stringent assessment process.
Relevant managers and teams responsible for procurement, recruitment, supplier onboarding and site operations are expected to remain alert to indicators of exploitation and to escalate any concernspromptly through the appropriate internal reporting channels.

Next Steps

VVB will continue to monitor the effectiveness of its actions against modern slavery and human trafficking and continue to raise awareness throughout the Company. Effectiveness will be reviewed through a combination of training completion, toolbox talk delivery, supplier and subcontractor review outcomes, labour agency assessment results, audit findings, SpeakUp or whistleblowing reports, corrective actions and lessons learned from any concerns raised.

VVB will use this information to support continuous improvement by:

Reviewing related procurement standards, including pre-qualification standards, supplier declarations, contractual expectations and escalation processes for the appointment and continued use of suppliers and subcontractors
Regularly training all employees on identifying potential modern slavery and human trafficking within our operations and supply chain, including through the completion of our mandatory Modern Slavery E- Learning which is incorporated into the new starter on-boarding process and regular site-based toolbox talks

Assessing the risks of modern slavery and human trafficking in our operations and our supply chain through heat mapping and auditing high risk suppliers and subcontractors
Sharing best practice to help raise awareness and reduce risk
Reviewing our working environments to ensure all employees are working in a safe environment

This statement is made in pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes VVB’s modern slavery and human trafficking statement for the financial year ending 31st December 2026 with approval by the Board of the VVB Group.