Against modern slavery

1. Purpose of this Statement

The purpose of this statement is to set out how the Total Integrated Solutions Group (TIS Group) approach eliminating modern slavery, human trafficking, forced labour and labour rights violations from business activities and their supply chain for the financial year ending 31^st December 2025.

It has been prepared by the Group People Manager and approved by the Chief Executive Officer in accordance with the roles and responsibilities set out below.

Under the Modern Slavery Act 2015, an organisation must publish an annual modern slavery statement on its website if it:

• Is a commercial organisation that supplies goods or services, and
• Carries out its business (or part of its business) in the UK, and
• Has a total annual worldwide turnover of £36 million or more.

The above criteria does not apply to the TIS Group. However, we feel that it is important to highlight our commitment to the Modern Slavery Policy regardless of our turnover.

2. Roles and Responsibilities

At the TIS Group:

• The Group People Manager is responsible for preparing an annual modern slavery statement.
• The Chief Executive Officer is responsible for approving this statement annually.
• The Leadership Team and Group People Manager are the designated internal contacts for employees who think they have spotted an instance of modern slavery or have a question about modern slavery.

3. Definition of ‘Modern Slavery’

Modern slavery is the severe exploitation of someone for commercial gain. It can include:

• Human trafficking – where someone facilitates or arranges the transport of another person for exploitation.
• Forced labour – where someone is forced to work through coercion (threats).
• Serfdom – where someone is forced to work through coercion and lives on another’s property.
• Bonded labour – where someone in poverty borrows money and is forced to work to pay off the debt.
• Descent-based slavery – where slavery is ‘passed down’ through a family line.
• Forced and early marriage – where someone is married against their will or is too young to consent to the marriage.

4. Preventing Modern Slavery

We will ensure that modern slavery does not form part of our business operations by:

• Carrying out a risk assessment to identify areas most at risk of modern slavery and identify measures we can put in place to remove and reduce risks.
• Where necessary, working with experts to identify steps we can take to reduce the risk of modern slavery.

We will ensure that modern slavery does not form part of our supply chain by carrying out due diligence on suppliers before entering into contracts with them.

Contracts with suppliers will state that:

• Suppliers’ performance with regards to modern slavery will be monitored alongside other parts of the contract.
• Suppliers are expected to monitor their own supply chains and report any breaches of the Modern Slavery Act 2015.
• Suppliers are not permitted to subcontract without our consent.
• If an instance of modern slavery is identified and not rectified to our satisfaction, we can terminate the contract with the supplier at no penalty to us.

5. If there is an instance of Modern Slavery

5.1 Immediate response

If an employee spots any instance of modern slavery, they should report it to the police immediately. If the situation is not an emergency, they can call the police on 101. If there is a risk of immediate danger, they should call 999.

5.2 If the instance is within our Organisation

If an instance of modern slavery is found within our organisation, the Chief Executive Officer will be informed immediately, and a member of the Leadership Team appointed to oversee all measures necessary to rectify the situation. Steps needed may include:

• Changing processes and policies.
• Providing more training to all employees.
• Reporting individuals who have breached the Modern Slavery Act 2015 to the appropriate authority.
• Where an employee has fallen short of the expectations of this policy, taking action in line with our company capability or disciplinary procedures.

5.3 If the instance is within our Supply Chain

If an instance of modern slavery is found within our supply chain, employees should notify the Head of Quality and Compliance who will decide appropriate action.

This may include:

• Offering advice to the supplier on steps they can take to eradicate modern slavery.
• Setting a deadline by which changes must be made.
• Terminating the contract with the supplier.

5.4 If the instance is outside of the UK

If modern slavery is identified outside of the UK, the appropriate response will depend on the local circumstances. For example, we may need to work with:

• non-governmental organisations (NGOs)
• local government and law enforcement
• industry bodies or trade union organisations

The immediate response should always be guided by what is safest for the employee and the potential victims.

6. Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Modern Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

7. Due Diligence Processes for Slavery and Human Trafficking

Risks of modern slavery are dynamic and change quickly.  Therefore, we regularly reassess and respond to the potential and actual risks in our business and supply chains.  As part of our initiative to identify and mitigate risk we actively review the following: –

• Where viable, we project manage our projects directly to ensure optimum control of the work environment.
• We limit the use of contractors to ensure optimum supervision of projects; where contractors are used, we build long lasting relationships and ensure they are fully vetted and screened to BS7858.
• Where possible we build long standing relationships with local suppliers and end clients and make clear our expectations of business behaviour.
• With regards to national or international supply chains, our point of contact is preferably with a UK company or branch, and we expect these entities to have suitable anti-slavery and human trafficking policies and processes. We expect each entity in the supply chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the supply chain, ultimately to the field or utility generator.
• We have in place systems to encourage the reporting of concerns and the protection of whistle blowers.

8. Supplier Adherence to Our Values

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values.

9. Raising concerns

Employees are encouraged to talk to the Group People Manager or a member of the Leadership Team if they have a question about modern slavery, or if they are not sure something they have seen counts as modern slavery.

The Modern Slavery Helpline can also provide advice. Their number is 08000 121 700.

10. Impact on Employees

An employee will face no negative consequences for:

• Alerting the appropriate authority and/or senior leaders to an instance of modern slavery.
• Raising concerns about our business practices.
• Seeking advice from an outside party about modern slavery.
• Asking questions about modern slavery.

If an employee feels they have suffered a detriment for any of the above, we encourage them to raise this using or company grievance procedure or our whistleblowing procedure. More information on these procedures can be found on My HR under Policy Acceptance.

11. Training

Raising awareness of modern-day slavery both within our business and our supply chains is an important part of our strategy. To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, we provide regular online training to all employees.

12. Our Effectiveness in Combating Slavery and Human Trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• Completion of Audits by the Leadership Team and the Compliance Manager.
• Use of an effective recruitment process which includes screening to BS7858 standards.
• Comprehensive vetting process for contractors which includes screening to BS7858 standards.
• All employee’s complete awareness training on Modern Day Slavery.
• Use of labour monitoring and payroll systems; and
• Ensure a level of communication and personal contact with the next link in the supply chain and that they have an understanding of our expectations.

13. Publishing this Statement

Our Modern-Day Slavery Statement is published on our Company Website.

A copy can also be requested by emailing HR@tis.co.uk.

This statement was approved by the Chief Executive Officer.

Reviewed: 10th January 2025