Modern Slavery & Human Trafficking Policy Statement 2025/26

Introduction

Conlon Construction Ltd (“Conlon”, “the Company”, “we” or “us”) is committed to preventing modern slavery, human trafficking, forced labour, servitude and other forms of labour exploitation within our business and throughout our supply chain.

We have a zero-tolerance approach to modern slavery and are committed to conducting our business ethically, responsibly and with integrity. We recognise that the construction industry can be exposed to modern slavery risks due to its reliance on subcontractors, labour providers, temporary workers and complex supply chains.

This statement sets out the steps Conlon Construction Ltd has taken during 2025 to prevent modern slavery and human trafficking and the further actions we intend to take during 2026.

This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 and reflects our commitment to continuous improvement in identifying, preventing and addressing modern slavery risks.

1. Company Structure

Conlon Construction Ltd is an established North West construction company, formed in 1961, with its registered office in Bamber Bridge, Preston, Lancashire. We deliver construction projects across the North West and work with public sector organisations, local authorities, universities and private sector clients.

Our work includes general construction, refurbishment, heritage, education, commercial, industrial, health and other construction projects.

Our business operates through a combination of directly employed staff and an extensive network of subcontractors, suppliers, specialist contractors and other business partners.

We recognise that our greatest exposure to modern slavery risk is likely to arise through our supply chain rather than through our directly employed workforce. We therefore take a proportionate, risk-based approach to managing these risks.

Ultimate responsibility for preventing modern slavery rests with the Company’s leadership. The Board of Directors has overall responsibility for ensuring that our policies, procedures and controls remain effective and comply with our legal and ethical obligations.

2. Supply Chain

Our supply chain includes subcontractors, specialist trades, suppliers of construction materials and products, plant and equipment providers, labour providers, consultants and other business partners.

A significant proportion of our supply chain is based within the North West. This local and regional approach provides greater visibility of our supply chain and enables us to develop long-term relationships with trusted subcontractors and suppliers.

However, we recognise that risks can exist at different levels of a construction supply chain, including further down the supply chain where visibility can become more limited.

We consider the following areas when assessing modern slavery risk:

• The type of trade or service being provided.
• The use of subcontracted or temporary labour.
• The use of labour providers or recruitment agencies.
• The use of low-paid or low-skilled workers.
• The use of migrant labour.
• The geographical location of workers and suppliers.
• The use of multiple tiers of subcontracting.
• Commercial pressures, including cost and labour shortages.
• The extent to which a supplier has its own policies and controls relating to modern slavery.
• Evidence of appropriate employment, right to work and payroll arrangements.

We expect our suppliers, subcontractors and business partners to share our commitment to preventing modern slavery and to comply with all applicable employment and human rights legislation.

Our existing Modern Slavery Policy requires supply-chain partners and business partners to implement appropriate procedures and confirm that they understand and will comply with Conlon’s requirements.

3. Supply Chain Audits and Due Diligence

Conlon recognises that effective prevention requires more than simply requiring suppliers to sign a policy.  We are therefore developing a more structured and risk-based approach to supply-chain due diligence.

During 2025, we continued to strengthen our existing controls through:

• Maintaining our Modern Slavery and Human Trafficking Policy.
• Including modern slavery requirements within our supply-chain appointment processes.
• Requiring relevant supply-chain partners to confirm their awareness of our requirements.
• Maintaining expectations that suppliers and business partners have appropriate modern slavery prevention arrangements.
• Raising awareness of modern slavery with employees and supply-chain partners.
• Maintaining reporting arrangements for concerns relating to modern slavery or labour exploitation.
• Continuing to work with and support organisations involved in tackling modern slavery, including Unseen.

Conlon previously supported Unseen, a charity providing support to survivors of modern slavery and human trafficking, and has used its specialist resources to raise awareness of the signs of modern slavery and the appropriate action to take.

2026 Supply Chain Audit Programme

During 2026, we will further develop our supply-chain audit and due-diligence arrangements.

This will include:

1. Introducing a formal modern slavery risk assessment for relevant suppliers and subcontractors.
2. Identifying higher-risk trades and suppliers for enhanced due diligence.
3. Introducing a proportionate supplier questionnaire covering modern slavery, labour practices, recruitment, right to work, payment arrangements and subcontracting.
4. Reviewing whether higher-risk suppliers have their own modern slavery policies, whistleblowing arrangements and appropriate employment practices.
5. Carrying out targeted audits of higher-risk suppliers and subcontractors where appropriate.
6. Reviewing the use of further subcontracting and requiring approval where work is passed to another organisation.
7. Recording and monitoring any corrective actions arising from audits or due-diligence checks.
8. Taking appropriate action where a supplier fails to meet Conlon’s requirements, which may include corrective action plans, additional monitoring, suspension of work or termination of the commercial relationship.

Our objective is to move towards greater visibility of our supply chain and ensure that modern slavery risks are actively managed rather than relying solely on contractual commitments.

4. Labour Provision

We recognise that labour provision can present particular risks within the construction industry, particularly where temporary labour, agency workers, migrant workers or multiple subcontracting arrangements are involved.

Conlon is committed to ensuring that all workers engaged on our projects are treated fairly, lawfully and with dignity.

Our controls include:

• Appropriate right to work checks for directly employed staff.
• Appropriate recruitment and onboarding procedures.
• Written terms and conditions of employment for employees.
• Monitoring of subcontractor and labour-provider arrangements.
• Requirements for suppliers and subcontractors to comply with employment legislation.
• We require all site operatives to provide evidence of their CSCS cards.
• Zero tolerance of forced, compulsory or trafficked labour.
• No requirement for workers to surrender passports or identity documents.
• No acceptance of recruitment practices that place workers in debt or require workers to pay inappropriate recruitment fees.
• Clear routes for workers and employees to raise concerns.
• Protection from detrimental treatment when concerns are raised in good faith.

Where labour agencies or other labour providers are used, Conlon will undertake appropriate due diligence to ensure that workers are recruited legally and ethically.

During 2026, we will strengthen our checks on labour providers and higher-risk subcontractors, including reviewing recruitment practices, right to work procedures, payment arrangements, deductions, worker documentation and the use of further labour intermediaries.

5. How We Prevent Modern Slavery

Conlon’s approach is based on the principles of Find it, Fix it and Prevent it.

Find it

We will seek to identify potential risks through:

• Supply-chain due diligence
• Supplier questionnaires
• Risk assessments
• Site observations
• Supplier and subcontractor audits
• Worker feedback
• Management engagement
• Whistleblowing and reporting arrangements
• Monitoring higher-risk trades and labour arrangements

Fix it

Where a concern is identified, we will investigate it promptly and sensitively.

Where modern slavery or labour exploitation is suspected, we will take appropriate action to protect affected individuals, investigate the circumstances and report matters to the appropriate authorities where required.

Where a supplier or subcontractor has weaknesses in its controls but there is no evidence of exploitation, we will seek improvement through corrective action, additional monitoring and engagement where appropriate.

Prevent it

Our preventative measures include:

• A Modern Slavery and Human Trafficking Policy
• Whistleblowing arrangements
• Employee induction and awareness
• Supply-chain requirements
• Recruitment and right to work checks
• Appropriate contractual requirements
• Supplier due diligence
• Assessing our performance against the Government’s risk identification and management Modern Slavery Assessment Tool (MSAT) achieving 90% in 2026
• Training for relevant employees
• Regular policy review
• Management oversight
• Promotion of a culture where employees and workers can speak up without fear of retaliation

Our Modern Slavery Policy is included within our employee handbook and induction arrangements and is communicated to employees and relevant supply-chain partners.

During 2025, our Modern Slavery Policy was reviewed and formally approved by the Managing Director. The policy reinforces our zero-tolerance position and provides clear routes for employees, suppliers and other business partners to raise concerns.

Training and Awareness

During 2026, Conlon will further strengthen staff awareness through modern slavery training.

Training will be prioritised for:

• Directors and senior management
• HR and recruitment staff
• Procurement and commercial teams
• Site managers and project managers
• Employees involved in appointing or managing subcontractors
• Employees responsible for managing labour providers

Training will cover:

• What modern slavery is
• The main risks within construction
• Indicators of forced labour and exploitation
• Responsible recruitment
• Right to work and worker documentation
• Recruitment fees and deductions
• The risks associated with labour providers and subcontracting
• How to raise concerns
• How concerns will be investigated and escalated
• The importance of protecting workers from retaliation

Training completion will be monitored as part of our ongoing review of the effectiveness of our modern slavery controls.

6. Policies and Supporting Procedures

Our commitment to preventing modern slavery is supported by our wider policies and procedures, including:

• Modern Slavery and Human Trafficking Policy
• Whistleblowing Policy
• Recruitment and onboarding procedures
• Equality, Diversity and Inclusion arrangements
• Health and Safety policies
• Employee Handbook
• Supplier and subcontractor appointment procedures
• Ethical and responsible procurement arrangements

During 2026, we will review these policies to ensure that they continue to support our modern slavery objectives and reflect current legislation, guidance and good practice.

Where appropriate, modern slavery requirements will be incorporated into procurement documentation, subcontractor requirements and supplier due-diligence processes.

7. Real Living Wage

Conlon recognises that fair pay and decent employment conditions are important safeguards against worker vulnerability and exploitation.

We are committed to paying our directly employed workforce fairly and ensuring compliance with statutory minimum pay requirements.

During 2026, Conlon will take steps towards paying the Real Living Wage to eligible directly employed employees and will review how this commitment can be reflected within our wider supply chain.

The Real Living Wage is independently calculated by the Living Wage Foundation and is intended to reflect the cost of living rather than simply the statutory minimum. The 2025/26 Real Living Wage rate for the UK is £13.45 per hour.

We recognise that responsibility for the pay of subcontracted workers normally rests with their employer. However, through our supplier due-diligence programme, we will seek greater assurance that workers within our supply chain are being paid lawfully and are not subject to exploitative deductions or unlawful working arrangements.

Our approach to fair pay will form part of our wider commitment to responsible employment and reducing the vulnerability of workers to exploitation.

8. Measuring Effectiveness

We recognise that having policies in place does not, by itself, demonstrate that modern slavery risks are being effectively managed.

During 2026, we will monitor the effectiveness of our approach through appropriate measures, including:

• Number of employees completing modern slavery training.
• Number of relevant suppliers completing modern slavery due diligence.
• Number of higher-risk suppliers identified.
• Number of supplier/subcontractor audits undertaken.
• Number of corrective actions raised and completed.
• Number of modern slavery concerns reported.
• The outcome of investigations into concerns.
• Number of labour providers subject to enhanced due diligence.
• Progress towards our Real Living Wage commitment.
• Annual review of the Modern Slavery Policy and related procedures.

The results of these activities will be reviewed by management and used to identify areas for further improvement.

9. Our 2026 Commitments

During 2026, Conlon Construction Ltd will continue to strengthen its approach to preventing modern slavery by:

• Providing modern slavery awareness training to relevant employees.
• Reviewing and updating supporting policies and procedures.
• Introducing a more structured, risk-based supply-chain due-diligence process.
• Identifying higher-risk trades, suppliers and labour arrangements.
• Carrying out targeted supplier and subcontractor audits.
• Strengthening due diligence on labour providers.
• Improving visibility of subcontracting and further supply chain tiers.
• Monitoring corrective actions arising from audits.
• Strengthening worker awareness of reporting and whistleblowing arrangements.
• Continuing to work with relevant specialist organisations and industry initiatives.
• Progressing our commitment to the Real Living Wage.
• Reviewing the effectiveness of our controls annually and using the findings to inform the following year’s action plan.

We recognise that modern slavery is a continuing and evolving risk and that no organisation can guarantee that its supply chain is entirely free from exploitation. Our commitment is therefore to continuous improvement, transparency, responsible procurement and taking appropriate action whenever risks or concerns are identified.

10. Board Approval and Declaration

Conlon Construction Ltd remains committed to preventing modern slavery and human trafficking in all areas of our business and supply chain.

This statement has been approved by the Board of Directors and is signed on behalf of Conlon Construction Ltd.

Signed: GE Parker

Position: Managing Director

For and on behalf of: Conlon Construction Ltd

Date approved: 13.08.26

Next review date: 13.08.27