Slavery and human trafficking statement

We strive to deliver as much of our output as possible through the use of our large, directly-employed workforce.

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• We have fair and transparent recruitment and resourcing procedures in relation to modern slavery and false employment in accordance with relevant standards and legislation.

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• All employees are paid at least the national minimum wage, with payments made directly to employees without delay.

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• No employees are forced to work more than the number of hours permitted by law.

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• All employees are entitled to terminate their employment without penalty at any time by giving the appropriate contractual notice.

Our philosophy with regards to suppliers of all goods and services is based on the development of mutually beneficial long-term relationships. Our expectations in terms of standards and conduct are made clear to all suppliers at the very beginning of our working relationships and are reinforced through our day-to-day dealings with all tiers of the supply chain.

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We will never knowingly support or deal with any business involved in slavery or human trafficking.

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In support of these principles, our business is committed to ensuring that:

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• Appropriate training is provided to relevant employees in order to raise awareness of modern slavery and human trafficking and the potential of such matters to impact on our business.

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• All staff are aware of our slavery and human trafficking statement and how to raise any concerns they may have in relation to modern slavery or human trafficking within our business and supply chain.

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• All commercial agreements with external suppliers include a requirement for our suppliers to operate in accordance with the Modern Slavery Act 2015.

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• Employees complete a training course via connected learning entitled ‘Modern Slavery Act Awareness’ that covers the essentials of the topic.

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In addition, J.N. Bentley Ltd has continued to meet its supply chain commitments on slavery and human trafficking by undertaking the following steps during the 2022 financial year:

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• Included Modern Slavery as a specific area of focus for all supplier assessments. In 2022, 144 no. new supplier assessments were undertaken.

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• Continued to ensure that all suppliers must sign to confirm that they are aware of the Modern Slavery Act 2015 and that they comply with all requirements that are set out in the Act as part of our Supplier Undertakings.

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• Included Modern Slavery as an area of focus for all supplier audits: 139 no. audits were carried out in 2022.

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• Developed our supply chain mapping by identifying the countries in which our suppliers source their materials and identified the top countries most at risk of Modern Slavery to J.N. Bentley Supply chain.

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• To reduce the potential risk, we continue to work closely with these key suppliers and keep modern slavery discussions at the forefront, to improve awareness of the Act and understanding the steps they are taking to ensure compliance across all tiers of their supply chain.

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• We have continued to improve modern slavery awareness with our site-based workforce (covering more than 700 no. employees) through Toolbox Talks and Site Manager Briefings, with posters displayed to reinforce the message. We acknowledge that it is critical that our site-based workforce is trained in how to identify the signs of modern slavery and trafficking and feel empowered to report any suspicions.

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• Our established Intranet (‘Compass’) houses all information and links relating the modern slavery and human trafficking to making it easy for all staff to find resources and details including reporting procedures.

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• We have continued to roll-out our ‘Modern Slavery Act Awareness’ via Connected Learning on Compass to new starters.

Our main objectives for 2023 financial year are as follows:

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Direct workforce

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• Continue our rollout of our existing ‘Modern Slavery Act Awareness’ connected learning training to relevant new starters.

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• Continue to review and update our ‘Modern Slavery Act Awareness’ training material (connected learning training and Toolbox Talks) to ensure it is current.

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Wider supply chain

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• Continue to engage with our suppliers on the topic of modern slavery and human trafficking, emphasising the importance of the act and understanding how they ensure compliance.

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• Continue with supplier audits aiming to audit between 10-20% of suppliers identified on risk-based approach.

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• Continue to improve our supplier mapping further by understanding all the tiers involved in our key supply chain to increase visibility and reduce any potential risk.

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This statement is made in accordance with our obligation under Section 54 of the Modern Slavery Act 2015 and constitutes the J.N. Bentley Ltd Slavery and Human Trafficking Statement for the financial year 1st January 2022 to 31st December 2022. It has been approved by the board of directors and it will be reviewed and updated on an annual basis.

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Paul R. Bentley, Managing Director, J.N. Bentley Ltd