Modern Slavery and Human Trafficking Policy

The Shore Group (TSG) refers to the following companies, and as such this policy applies to all listed companies:

The Shore Grp Holdings Ltd and subsidiaries:

The Shore Grp Solutions Ltd

Shore Grp Resources LLP

The Shore GRP (UK) LLP

The Shore Grp (Kent) Ltd

The Shore Grp LTD

1. Policy statement

The Shore Group is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses. Modern slavery is a crime and a violation of fundamental human rights. All types of modern slavery have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain.

We are committed to ensuring that our staff and any workers we supply (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our business relationships, consistent with our disclosure obligations under the Modern Slavery Act 2015. As part of this process, we have undertaken a review of our supply chain to identify and assess potential risk areas.

We expect high ethical standards from all our subcontractors, suppliers, and other business partners. This includes respecting and protecting the human rights of their employees, those of their suppliers and business partners, and the communities affected by their operations. We have made these expectations contractual where possible.

Suppliers must ensure their operations are free from modern slavery and human trafficking practices, both in the UK and globally, including within their own supply chains and external business relationships.

2. Identified risk areas in our business and supply chains

We have carried out a risk assessment of our business operations and supply chain and have identified the following areas where the risk of modern slavery is the greatest:

• The provision and employment of low-skilled manual labour roles in construction and logistics sectors

• The use of migrant or temporary workers who may be vulnerable to exploitation -  Indirect labour employment through third parties such as subcontractors or recruitment agencies

• Material supplies from industries which have a high risk of modern slavery Indirect material supplies from countries or regions with weak enforcement of labour laws and protection

3. Policy implementation

3.1 Supplier Due Diligence

We undertake due diligence when onboarding new suppliers and subcontractors and conduct regular reviews of our existing business partners, which includes:

• Evaluating suppliers for the risk of modern slavery and human trafficking

• Conducting audits or assessments in higher-risk situations.

• Working collaboratively with suppliers to improve substandard practices through corrective action plans.

• Invoking sanctions, up to and including termination of business relationships, for suppliers that fail to meet our standards.

• Participating in collaborative initiatives and engaging with like-minded businesses to eradicate modern slavery throughout supply chains.

• Ongoing review of labour only supply to help ensure that all human rights are being observed and there is no exploitation or modern slavery present

3.2  Candidate Compliance

We are committed to supplying our clients with fully compliant workers. All candidates onboarded are subject to strict compliance checks. These include verifying identity, right to work and compliance with all applicable laws, including the UK Modern Slavery Act 2015.

Our Compliance department carry out weekly and monthly candidate audits to unsure that all procedures are being observed.

We are regularly audited by our clients and other stakeholders to ensure we are upholding our legal and contractual obligations in the supply of labour.

3.3  Internal Processes

All employees are provided with clear employment contracts compliant with local laws. We ensure fair and respectful treatment, free from discrimination, victimisation, or harassment on any protected grounds.

3.4  Worker Rights and Protections

We uphold the following fundamental principles across our business and supply chains:

• Freedom to Terminate Employment without penalty, following appropriate notice

• Freedom of Movement, ensuring no restrictions on workers' mobility

• Freedom of Association, supporting workers’ rights to unionize and collectively bargain should they choose

• Prohibition of violence, harassment, and intimidation in all circumstances

• Prohibition of worker-paid recruitment fees, these are always covered by the employer

• No overtime shall be compulsory and is allocated on a voluntary basis only

• Prohibition of Child Labour, adhering strictly to ILO and local laws (no workers under 16; no hazardous or night work under 18). If under 18s are employed, young worker risk assessments must be undertaken

• Discrimination of any form will not be tolerated and will result in disciplinary action

• Prohibition of debt bondage internally and throughout the supply chain

• All documentation must remain with the worker at all times

3.5 Remedy and Justice

In the event of discovering modern slavery internally or within the supply chain, we are committed to providing victims with access to remedy, compensation, and justice. This includes:

• Investigating concerns promptly.

• Working with appropriate organisations to support victims.

• Referring cases to relevant enforcement authorities when needed.

4. Training and awareness

All staff receive training and awareness materials related to modern slavery and human trafficking. Labour operatives are informed of relevant risks at registration. Awareness training includes:

• Identifying signs of modern slavery.

• How to report concerns.

• Roles and responsibilities under the Modern Slavery Act.

• Toolbox Talks delivered where the need is identified.

Any staff, workers or third parties are encouraged to report concerns or suspicions to the Compliance Team or via our anonymous reporting form. All reports are taken seriously and investigated promptly by senior leadership.

5. Whistleblowing

We encourage all employees, customers and subcontractors to report any concerns related to modern slavery or human trafficking in our business or supply chain. For further details, please refer to our Whistleblowing Policy. There is also an anonymous reporting mechanism available through our feedback poster and QR which is placed on all sites and on candidate registration forms.

6. Supplier Code of Conduct

Our Supplier Code of Conduct sets out the ethical expectations we require from our business partners. Suppliers must:

• Provide safe, fair, and respectful working conditions.

• Act ethically and comply with all applicable labour laws.

• Cooperate with us to improve standards where required.

• Serious breaches of our code may result in the termination of the supplier relationship.

7. Key Performance Indicators

We monitor our progress in tackling modern slavery using KPIs such as:

• The percentage of suppliers/subcontractors providing their own modern slavery statements and commitments.

• The level of modern slavery awareness among our staff through training records.

• Supplier adherence to our Supplier Code of Conduct.

• Percentage of suppliers assessed for modern slavery risks.

8. Communication, Approval and Review

The Shore Group’s senior management are committed to the elimination of modern slavery and human trafficking both internally and throughout the supply chain. This policy statement is approved by senior management and the results of monitoring and assessment are reported to senior management on a regular basis.

We are committed to transparent communication and engagement with our employees, suppliers, and stakeholders and as such it is shared with all employees at onboarding and is available on the company intranet. The policy is also available on the company website and the UK Government modern slavery registry.

The policy is reviewed annually and any updates are communicated by updating all the relevant platforms and informing clients.