Modern Slavery Policy

Purpose

SPS (South) Ltd is committed to preventing modern slavery, forced labour and human trafficking in all our business activities and supply chains. This policy sets out our approach to identifying, managing and mitigating the risk of modern slavery in compliance with the UK Modern Slavery Act 2015, and reflects good practice expectations for 2026.

Scope

This policy applies to all employees of SPS (South) Ltd, all suppliers, contractors, consultants and labour providers, and any individual or organisation working for, or on behalf of, SPS (South) Ltd. It applies to all operations undertaken within the United Kingdom.

Our Organisation and Supply Chain

SPS (South) Ltd is a UK-based construction and retrofit contractor operating primarily across the South of England. We work with a range of delivery partners, suppliers and service providers. While operations are predominantly UK-based, we acknowledge risks may exist and take a proactive approach to managing them.

Policy Statement

SPS (South) Ltd has zero tolerance for modern slavery and human trafficking. We act ethically, respect workers’ rights and dignity, implement effective controls, and work with stakeholders who share our commitment.

Roles and Responsibilities

Senior Management provides oversight; procurement and commercial functions assess supply chain risk; operational management remains alert to indicators of exploitation; all employees are expected to comply with this policy and report concerns.

Risk Assessment and Due Diligence

We adopt a risk-based approach including supplier checks, right-to-work verification, review of labour practices, and ongoing monitoring.

Supply Chain Expectations

Partners must comply with the Modern Slavery Act 2015, ensure employment is freely chosen, pay workers lawfully, and provide safe working conditions.

Reporting and Whistleblowing

Concerns may be raised via line management, senior management or whistleblowing procedures. Reports are treated seriously and without retaliation.

Training and Awareness

Training and awareness activities are provided proportionate to role and reviewed periodically.

Breaches

Breaches may result in remedial action, termination of contracts, disciplinary action or referral to authorities.

Monitoring and Review

This policy is reviewed annually and updated as required.

Approved and signed on behalf of SPS (South) Ltd

Signed:

Managing Director

For and on behalf of SPS (South) Ltd

March 2026