Introduction

This statement sets out the actions of Phoenix ME Ltd and our associated Companies to eliminate any potential modern slavery risks related to our business.

Phoenix ME Ltd and our associated Companies are committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.

This statement relates to actions and activities during the financial year 1 October 2025 to 30 September 2026.

Organisational structure

Phoenix ME Ltd and our associated Companies are a provider of Electrical and Mechanical installation, testing and commissioning services and IT installations offering complete Infrastructure solutions. We are also the Principal Designer and Principal Contractor to numerous work sectors, including commercial offices, banking establishments, data centers, education, government buildings, residential infrastructure, retail and pharmaceutical.

The labour supplied to Phoenix ME Ltd and our associated companies, in pursuance of operations carried out across the United Kingdom and Europe, shall adhere to all applicable regulations.

Definitions

Phoenix ME Ltd and our associated Companies considers that modern slavery encompasses:

• human trafficking
• forced work, through mental or physical threat
• being owned or controlled by an employer through mental or physical abuse of the threat of abuse
• being dehumanised, treated as a commodity or being bought or sold as property
• being physically constrained or to have restrictions placed on freedom of

Commitment

Phoenix ME Ltd and our associated Companies acknowledge our responsibilities in relation to tackling modern slavery and commit to complying with the provisions in the Modern Slavery Act 2015. Phoenix ME Ltd and our associated Companies understand that this requires an ongoing review of both our internal practices in relation to our labour force and, additionally, our supply chains.

Phoenix ME Ltd and our associated Companies do not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to Phoenix ME Ltd or our associated Companies in the course of delivering our services is obtained through slavery or human trafficking. Phoenix ME Ltd and our associated Companies strictly comply with all minimum standards required under relevant employment legislation in the UK and Europe.

Supply chains

Phoenix ME Ltd and our associated Companies are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their workers’ working conditions. Serious violations of the Companies supplier code of conduct will lead to the termination of the business relationship.

Potential exposure

Global data shows that the Construction industry has a higher exposure to slavery/human trafficking.

Phoenix ME Ltd and our assocaited Companies as a service provider within the construction industry has therefore taken this possible exposure to slavery/human trafficking seriously and has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

Steps

Phoenix ME Ltd and our associated Companies carry out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in our Company or supply chains, including conducting a review of the controls of our suppliers and subcontractors.

The Company has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Company has taken the following steps to ensure that modern slavery is not taking place:

• reviewed our supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery
• included in our quality audits measures to identify and assess the potential risks in its supply chains
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping
• undertake annual impact assessments of our services upon potential instances of slavery
• created action plans to address risk to modern slavery

Performance indicators

The Company has set the following key performance indicators (KPI’s) to measure its effectiveness in ensuring modern slavery is not taking place in the organisation or its supply chains:

• requiring all employees to undertake training on modern slavery
• updating our system for supply chain verification, whereby Phoenix ME evaluates potential suppliers
• updating its system for supply chain verification, whereby the Commercial department evaluates potential suppliers before they enter the supply chain; and
• reviewing its existing supply chains whereby the Company will re-evaluate all existing suppliers in light of the Modern Slavery Act 2015

Responsibility for Phoenix ME Ltd and our associated Company’s anti-slavery initiatives is as follows:

Policies: HR department.

Risk assessments: ESG department and the project team.

Investigations/due diligence: HR are responsible for investigations and legal are responsible for due diligence in relation to known or suspected instances of slavery and human trafficking.

Training: Training is delivered by the Learning and Development and HSEQ Department to ensure our employees, subcontractors and workers better understand and respond to the identified slavery and human trafficking risks.

Policies

The Company has the following policies which further define our stance on modern slavery, and which clearly stipulate our zero-tolerance policy towards modern slavery.

Modern slavery policy

We have a comprehensive Modern Slavery policy which stipulates the organisational processes and procedures and expectations across our supply chain in relation to modern slavery and human trafficking.

Whistleblowing policy

We encourage all our workers, customers and other business partners to report any concerns related to the direct activities or the supply chains of our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact HR or use an anonymous form to make a confidential disclosure.

Recruitment/Agency workers policy

Phoenix ME Ltd and our associated Companies strive to use only specified, reputable employment agencies, with which we have a preferred supplier agreement to source labour. The organisation strives to verify the practices of any new agency it is using before accepting workers from that agency.

Anti-bullying and anti-harassment

The Company operates a zero-tolerance approach to bullying and harassment. The purpose of our anti-bullying and anti-harassment policy is to ensure a safe, respectful, and inclusive workplace. It aims to:

• prevent bullying and harassment by setting clear expectations for behaviour
• protect employees from any form of abuse, ensuring their wellbeing
• promote a positive work environment where everyone feels valued and respected
• provide mechanisms for reporting and addressing incidents effectively

Embedding the principles

Phoenix ME continues to embed the principles of this statement through a requirement for all employees to complete online training on modern slavery.

The Company’s modern slavery training, delivered via our LMS platform, is designed to raise awareness and ensure staff are equipped to recognise and respond to potential concerns. The training covers:

• Defining modern slavery
  Explains what modern slavery is, including a clear overview of the term and how it encompasses practices such as forced labour, human trafficking, and exploitation.
• The facts about modern slavery
  Presents key facts and statistics to highlight the scale of modern slavery globally and in the UK, reinforcing the relevance of the issue to all sectors.
• Who is affected
  Identifies the individuals and groups most vulnerable to modern slavery, including men, women, and children, and those working in lower-paid or unregulated sectors.
• Different types of modern slavery
  Provides an overview of the various forms modern slavery can take, such as domestic servitude, debt bondage, child labour, and criminal exploitation.
• Spotting the signs
  Teaches employees how to recognise the warning signs that may indicate someone is a victim of modern slavery, whether within the workplace, on sites, or in supply chain settings.
• How we can help
  Highlights the role all employees play in preventing modern slavery, including creating a culture of awareness, taking concerns seriously, and signposting support.
• Reporting suspicions
  Offers instructions on how to report concerns or suspicions of modern slavery.

The training also signposts our internal Modern Slavery and Human Trafficking Policy and reinforces the importance of proactive action to help prevent exploitation and human trafficking. This supports the protection of our workforce, the safeguarding of company profits, and the preservation of Phoenix ME’s reputation and integrity.

Awareness-raising programme

As well as training employees to help embed the principles of this statement, the Company raises awareness of modern slavery issues by circulating a series of emails to employees and its supply chain and publishing articles on its internal communications platforms.

The information circulated explains to employees:

• how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
• how to identify the signs of slavery and human
• what initial steps should be taken if slavery or human trafficking is
• how to escalate potential slavery or human trafficking issues to the relevant parties within our organisation.
• what steps our organisation should take if suppliers or contractors do not implement antislavery policies in high-risk scenarios, including their removal from our supply

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Approved by the Board and signed on their behalf by