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Keltbray Group (Holdings) Limited (referred to as Keltbray Group herein), incorporates organisations that make
up the Keltbray Group of companies. These organisations are listed at the end of this statement.

Keltbray Group is a UK leading specialist engineering and construction business, which provides engineering,
construction, demolition, decommissioning, remediation, environmental services, reinforced concrete structures,
rail and power distribution and transmission solutions to public and private sector clients. In the main these
services are provided on a self-delivery basis. The Group is a key player in developing and maintaining Britain’s
built environment and infrastructure, and operates in highly regulated environments.

We have implemented policies and procedures to ensure fair and ethical treatment, these include:

  • Equal opportunities and anti-discrimination
  • Training and development
  • Health, safety and wellbeing
  • Fair pay
  • Whistle-blowing

Keltbray Group have signed up to the Gangmasters & Labour Abuse Authority construction protocol and we are
signatories of this. It is aimed at eradicating slavery and labour exploitation in the construction industry. The
construction protocol commits signatories to:

Supply Chain

Our external supply chain is predominantly made up of organisations utilised across our Built Environment and
Infrastructure divisions. We directly contract these organisations to complete work on our behalf or supply
materials or labour.

The Keltbray Group due diligence process for suppliers incorporates a review of the controls undertaken by the
supplier. All organisations that the company deals with are required to confirm that both they and their supply
chain are not knowingly involved in slavery and human trafficking. Such a declaration is required by all companies
in order to be added to the company’s preferred supplier list.

Risk

Where we have most control, in respect of modern slavery and human trafficking, is in recruitment of direct
employees. We have procedures in place to ensure that recruitment is completed in line with regulatory
requirements and our people have access to rights and appropriate conditions. We view this area as low risk.
The highest risk to Keltbray Group is through our temporary staff whom are recruited via recruitment
agencies. Our recruitment process conforms to regulatory requirements and the fair and ethical treatment of
temporary employees.

In 2019, we enhanced our process for reviewing recruitment agencies by auditing them across a range of topics,
including; modern slavery, business ethics, discrimination and bullying, recruitment practice, health and safety,
payroll and competence. We continue to periodically audit our roster of recruitment agencies as part of a
continuous improvement process and feedback is provided to the recruitment agencies to assist them in improving
their systems and processes.

In 2020, we acknowledged that further work was required with our wider supply chain as part of our approach to
risk management and mitigation to confirm modern slavery requirements are in place. As a result of this, we have
designed and implemented a new pre-qualification questionnaire and onboarding process for agencies that
require the suppliers to produce documentation to confirm that they are compliant with requirements for modern
slavery and payment of wages. This information is reviewed externally by our insurers who confirm that all of the
necessary standards are met for supply. An agency cannot be an approved supplier without providing this
documentation and subsequently this reduces the risk and we can confirm that we have found no signs of modern
slavery in our supply chain.

In 2020, we identified that our whistleblowing policy warranted improvement. As a result of this, we have updated
the policy to make it robust and consistent with Keltbray’s open and supportive culture.

Training

In 2019, we introduced the training modules for modern slavery, corporate social responsibility, and fairness and
inclusion. The modules were made available for voluntary completion as part of the Keltbray Learning and
Development package.

In 2020, further enhancements were made to the modern slavery training, including guidance on ‘right to
work’ checks.

In early 2021, we launched a digital learning platform that is accessible to all Keltbray people that includes
learning in Modern Slavery and Equality, Diversity and Inclusion. These will be mandated at milestones throughout
the year.

 

Vince Corrigan
Group Chief Operating Officer
Date: April 2021

Annex

Subsidiary companies of Keltbray Group (Holdings) Limited meeting the criteria to require the preparation of an
annual slavery and human trafficking statement, in accordance with the Modern Slavery Act 2015, that are
included within the scope of this statement:

  • Keltbray Limited
  • Keltbray Aspire Limited
  • Keltbray Group Limited
  • Keltbray Plant Limited
  • Keltbray Structures Limited