Morgan Sindall : 2022 Modern slavery statement

OUR VALUES AND COMMITMENTS

Our commitment to human rights is ingrained in our culture

Protecting

people

Developing

people

Our Total Commitments, which have guided our responsible business strategy since 2006 and are driven by the Board, include protecting people, working together with our supply chain and enhancing communities. Our endeavours to protect the rights of our employees, subcontractors and the people living in the communities where we work underpin these three commitments. As we are a decentralised business, our divisional managing directors

are responsible for embedding the Total Commitments into their businesses and at least once a year the Board reviews the approach and progress being made by management to identify areas where risk of human trafficking and modern slavery may occur.

We have adopted a proactive and holistic approach to managing the risks and minimising the likelihood of modern slavery and human trafficking happening both in our own operations and our supply chain. This includes periodic risk assessments, thorough due diligence, continuous engagement with employees

and suppliers, collaboration with external stakeholders and remediation when necessary. At the end of 2022, we undertook a gap analysis of our management of modern slavery risks. As a result, we are developing a clearer roadmap for identifying and addressing modern slavery risks in our operations and supply chain; more detail will be provided during our 2023 reporting cycle.

Improving the

environment

Working together with our supply chain

Our Total Commitments are aligned with the UN Sustainable Development Goals, the following six being those where we believe we can have the biggest impact:

OUR VALUES AND COMMITMENTS continued

We work collaboratively with suppliers, civil society, the government and other businesses on human rights to inform our approach, share our experiences and help address root causes and influence systemic positive change. Our relationships with our supply chain are essential in the successful delivery of our projects and we regard them as our partners. We provide additional resources and training to support our supply chain in preventing and addressing any threat to human rights within their own organisations. Contractors are made aware of their obligations and responsibilities towards our sustainable procurement principles and our human rights commitments through the appropriate contractor agreements, i.e. where we have a direct contract for goods or services.

We are committed to building awareness and knowledge of our employees and suppliers on human rights throughout the Group.

We encourage anyone to speak up, without retribution, about any concerns they may have, and our policies and processes reflect this.

We provide a free 24-hour whistleblowing service operated by an independent third party, Safecall, to all our employees and subcontractors to raise any concerns about behaviours or decisions that do not uphold the standards set by our Group Code of Conduct, modern slavery policy, human rights policy and any other policy. Our internal audit programme monitors compliance with our policies and procedures aimed at identifying, preventing and mitigating human right risks, and remediating any impacts our operations may have caused or contributed to.

Our human rights policy, which was adopted by the Board in August 2022, clearly supports the UN Guiding Principles on Business and Human Rights and the Universal Declaration of Human Rights, and our Code of Conduct provides a framework for how we should act when engaging with our clients, colleagues and suppliers.

We continuously evaluate our operations and supply chain to identify, assess and address human rights risks. In 2022, we partnered with Unseen, an anti-slavery charity offering a range of services to help companies stay on top of forced labour risks in their businesses and supply chains. We commissioned Unseen to conduct

a gap analysis across our business and support us in developing a plan for prioritised action. The gap analysis will evaluate our ongoing implementation of due diligence and processes to identify and mitigate potential impacts on human rights. The gap analysis was undertaken in late 2022 and, in 2023 an action plan will be developed and rolled out, spearheaded

by a newly formed, cross-divisional forum that will include a member of Unseen. The forum will help facilitate implementing Unseen's recommendations.

Other key achievements for our management of modern slavery risk in 2022 includes:

• We achieved ISO 20400:2017 Responsible Procurement accreditation. The Standard is based on core principles of sustainability aligned to the UN Sustainable Development Goals and covers an assessment of ethical labour practices including subcontracted work activity.

• We achieved accreditation in ELS BES 6002 Ethical Labour Sourcing standards. The assessment included an examination of ethical approaches and human rights due diligence when sourcing labour and the Group was evaluated as being in the top quartile. We also appointed BRE Global to carry out the assessment for us rather than self-assessing, providing an additional level of transparency.
• We updated our Modern Slavery and Human Rights Minimum Trading Standard for inclusion in new contracts. This will commence in 2023.
• We rolled out an updated and expanded toolkit for employees including site posters, site inductions, supervisor briefings, toolbox talks and links to learning materials. These new resources are video-based and interactive
  to encourage viewers to engage with the material, making it more effective.
• Construction carried out 33 ethical site surveys in partnership with global data validation company Achilles, which included over 1,000 direct conversations with site operatives.
• We continued to roll out mandatory e-learning course on our Code of Conduct for all new and existing employees, including a section on modern slavery.
• We liaised with Safecall (our raising concerns helpline service provider) to ensure that their teams can detect if a call relates to a modern slavery issue.

OUR BUSINESS AND SUPPLY CHAIN

Our business

Morgan Sindall Group is a leading UK construction and regeneration group with an annual turnover of £3.6 billion. We generate cash through our construction activities and invest in long-term regeneration schemes, which in turn create opportunities in construction. We deliver for the public, commercial and regulated sectors. We operate through five divisions: Construction

• Infrastructure, Fit Out, Property Services, Partnership Housing and Urban Regeneration, with an aggregate of over 70 offices and 350 project sites located around the UK. For the purposes of this statement, we treat our joint venture entities (where we are responsible for the management and operation of the joint venture) as part of our supply chain. Our joint venture partners, in the context of this statement, are primarily other large main contractors. Our customers are drawn from the public sector, regulated industries, and
  a variety of commercial sectors. Appendix 1 contains more detail of our markets and business activities.

Our workforce is made up of over 7,000 direct employees, 4% of whom are weekly-paid site operatives covered by collective bargaining agreements, and we outsource a small number of IT staff and office cleaning personnel.

We respect freedom of association and our employees' right to join, or not to join, third-party organisations such as labour unions or other lawful organisations of their own selection, along with the right to bargain or not bargain collectively, in accordance with local laws, without fear of reprisal, intimidation or harassment. More information is included within our human rights policy, which can be found in the Governance section on our website,

under 'Policies and assurances'.

Key performance indicators

As a Group, we report against the following KPIs: employee training; investigations undertaken into reports of modern slavery and remedial actions taken in response; and evaluation of our labour practices against ELS BES 6002. See page 8 for information on employee training and page 7 for information on our reporting and remedial processes. We have successfully completed ELS BES 6002 accreditation which included baseline standards in 12 key areas, including management systems, assurance, supply chain management and reporting. We scored a three or four (four being the highest) in nine categories and surpassed baseline requirements on all criteria. As part of our ongoing commitment to transparency and improving ethical labour sourcing practices in our own business and supply chain, the assessment scoring was completed independently by BRE and the Group will undergo a reassessment in late 2023.

Our supply chain

Our decentralised business means that at any given time we can have around 20,000 subcontractors providing a wide range of services including mechanical and electrical installations, labour, goods, and services for our sites and offices. However, all our procurement is carried out with UK-based suppliers, although we recognise that some of these suppliers may source products from other countries.

We founded our Morgan Sindall Supply Chain Family over 20 years ago so that the businesses can develop close relationships with their suppliers. Members benefit from training, design support, on-site practical advice, access to contract information and upcoming projects and a dedicated relationship management team. To date, almost 400 manufacturers and suppliers are registered with our Morgan Sindall Supply Chain Family. In addition, we are a founding member of the Supply Chain Sustainability School and continue to partner with them to help suppliers develop skills and provide free training, including modern slavery modules that address how to identify and manage potential incidents of modern slavery. As at the end of 2022, 2,778 of our suppliers were registered with the School, up from 2,595 in 2021.

Our Group director of sustainability and procurement also chairs the School's Labour Group, which looks to set minimum standards for the industry. The leadership position our director holds provides us with additional foresight on emerging trends and regulation. The School also manages the 'People Matter Charter', which sets out several commitments that apply to clients, main contractors and the supply chain, including due diligence in protecting human rights, identifying and reporting labour exploitation, paying the living wage and ensuring those employed in the supply chain receive the payments and benefits to which they are entitled. The Group is

a signatory of the Charter.