NEWTECNIC ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY

INTRODUCTION

Newtecnic Limited is a world-leading firm of engineering designers, architects and contractors, providing consulting services for buildings, infrastructure, and the environment. We operate across a range of sectors including commercial, cultural, residential, transport and administration. We operate across the world, including the UK, USA and the Middle East. The supply chains we are involved with are global.

POLICY STATEMENT

Newtecnic Limited strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

This policy deals with the specific issues associated with modern slavery and human trafficking.

Modern slavery is a crime and a violation of an individual’s fundamental human rights. It takes various forms, such as slavery, servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in within the businesses making up the Kier Group or in any of our supply chains.

We are also committed to ensuring there is transparency in our own businesses and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we will include specific prohibitions concerning modern slavery, whether of adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards. Kier’s approach will be to work with our supply chain partners to improve performance standards but ultimately, we may have to review whether we can continue on-going relationships if our standards cannot be met.

COMMITMENTS

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.

The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy.

We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.

We are committed to maintaining our accreditation as a Living Wage Employer, as defined and accredited by the Living Wage Foundation.

We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked-based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.

Consistent with our risk-based approach we may require:

Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct

Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to our Code of Conduct

As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.

As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.

If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

WHAT DOES THIS POLICY APPLY TO?

This policy applies to all full and part-time employees, as well as temporary staff, whenever they are working. It also applies to agents, contractors and other third parties acting on our behalf in any capacity.

This policy does not form part of any employee's contract of employment and we may amend it at any time.

RESPONSIBILITY FOR THE POLICY

The Newtecnic Limited C-Suite responsibility for ensuring this policy complies with our legal and ethical obligations. This includes the primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it and engaging internal audit resource to audit internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

COMPLIANCE WITH THE POLICY

You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our businesses or supply chains is the responsibility of all of us. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You are expected to report as soon as possible: whether you know or suspect any instance of modern slavery is occurring in any part of our businesses or supply chains; and whether you know or suspect a breach of this policy is/has occurred to your line manager, or a member of the C-Suite.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any of our businesses or supply chains constitutes any of the various forms of modern slavery, raise it with your line manager, or a member of the C-Suite.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our businesses or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform C-Suite immediately.

COMMUNICATION AND AWARENESS OF THIS POLICY

Regular training on this policy and on the risks our businesses face from modern slavery in its supply chains will be provided as necessary.

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

BREACHES OF THIS POLICY

Non- compliance with this policy by employees may result in disciplinary action up to and including summary dismissal, and by contractors, agents or other third parties working on our behalf, in termination of contract.

SPEAKING UP

If you have a concern or suspect a violation of this policy, we want you to speak up immediately. Speaking up can be a difficult thing to do, so be reassured that all information received will be treated seriously and investigated appropriately. If you act in good faith, believing your information is accurate, we will protect you even if you are wrong. Some concerns can be addressed by speaking to the person whose conduct is the cause for concern. We understand that this is not always possible, so we suggest that you speak to your line manager. If, for whatever reason, you do not feel comfortable doing this, you can contact any member of the C-Suite.