Modern Slavery Statement

1. Introduction

Modern slavery is a despicable form of organised crime in which people are exploited for criminal gain. It is inhumane, unethical and damaging to society, yet it remains an issue in corporate supply chains around the world.

Hargreaves Services plc and all its subsidiary undertakings, together referred to as Hargreaves or the Group, are committed to the eradication of slavery and human trafficking. This statement is made in compliance with section 54(1) of the Modern Slavery Act 2015.

Hargreaves will not knowingly use forced labour, slavery or unlawful child labour in the provision of any of its services or products. Nor will Hargreaves knowingly accept services or products from suppliers that employ or use forced labour, unlawful child labour or any form of slavery.

This statement reflects Hargreaves’ commitment to acting ethically and with integrity in all its business relationships. It also demonstrates the Group’s commitment to implementing and enforcing effective systems and controls to prevent slavery and human trafficking from taking place within its operations or supply chains.

The statement sets out Hargreaves’ policy and the steps being taken to prohibit all forms of forced labour and slavery throughout the Group’s supply chain.

This statement constitutes Hargreaves’ slavery and human trafficking statement for the financial year ended 31 May 2025. It was approved by the Board on 23 September 2025 and applies to Hargreaves Services plc and the subsidiaries listed in Appendix 1.

2. Structure, Business and Supply Chains

Hargreaves is a diversified group delivering services to the industrial and property sectors and supporting key industries in the UK and South East Asia. The Group has operations in the UK, Asia and South Africa and employs approximately 1,531 people worldwide.

A full list of subsidiaries is included in Appendix 1.

Hargreaves provides critical support to a number of core industries, including energy, environmental services, UK infrastructure and manufacturing. Its services include materials handling, mechanical and electrical contracting, logistics and major earthworks.

Hargreaves Land focuses on the sustainable development of brownfield sites for residential and commercial purposes.

The Group’s supply chain includes:

  • Material and equipment suppliers
  • Subcontractors
  • Employment and labour agencies

Due to the locations in which Hargreaves operates and the nature of the activities undertaken, the overall risk of employing forced labour or individuals who may be subject to human trafficking is considered generally low.

However, the Group has identified areas of the business with an increased risk of exposure to modern slavery. Systems and processes, supported by periodic internal checks and reviews, have been introduced to reduce this risk. Further details are provided below.

3. Policies

Hargreaves has implemented a comprehensive suite of policies, policy statements and procedures, which are reviewed and approved by the Board annually.

These include:

  • Code of Ethics
  • Anti-Corruption and Bribery Policy
  • Whistleblowing Policy
  • Group Health and Safety Policy Statement
  • Group Competition Law Statement
  • Environmental Policy
  • Sustainable Supply Chain Policy

Copies of these policies and statements can be found on the Hargreaves Services website.

During the financial year ended 31 May 2025, Hargreaves introduced anti-slavery and human trafficking training for relevant employees. This training supports the Group’s Anti-Slavery and Human Trafficking Policy.

The policy outlines the principles and standards adopted across the Group to help prevent modern slavery from taking place within the business or its supply chains. It also explains how employees can raise concerns about any issue or suspected instance of modern slavery within any part of the Group’s operations or supply chains.

The Hargreaves Whistleblowing Policy encourages employees to raise concerns in the knowledge that:

  • Their concerns will be taken seriously
  • Concerns will be investigated where appropriate
  • Confidentiality will be respected
4. Due Diligence Processes

Business units have implemented systems and processes to confirm the identity of employees and ensure that they have a legitimate right to work in the UK. These measures help to reduce the risk of employing forced labour or individuals who may be subject to human trafficking.

New suppliers in the UK are required to complete the Group’s supplier onboarding process. This includes due diligence relating to compliance with the Modern Slavery Act 2015.

5. Risk Assessment and Management

The risk of forced labour or human trafficking is considered higher in relation to labour deployed on sites and contracts. The use of subcontractors and employment agencies may also increase the risk of modern slavery taking place on Hargreaves sites or within the Group’s supply chain.

These risks are managed through the due diligence processes described above.

Where an increased risk relating to modern slavery has been identified, the relevant business unit has introduced additional internal checks and reviews.

For example, the business carries out random checks on employment agencies, requiring them to produce evidence of eligibility to work in the UK and copies of payslips.

6. Key Performance Indicators

Where an increased risk of forced labour or human trafficking has been identified, the relevant business unit has implemented systems and processes to reduce that risk. These measures are supported by periodic internal checks.

The following key performance indicators will be measured during the financial year ending 31 May 2026:

  1. The percentage of relevant employees who have received anti-slavery and human trafficking training.
  2. The number of modern slavery incidents identified within the business or its supply chains.
7. Communication and Training

The Group has introduced online anti-slavery and human trafficking training for relevant employees.

The purpose of this training is to:

  • Raise awareness of modern slavery
  • Help employees recognise potential warning signs
  • Explain how employees can report concerns or suspected instances of modern slavery
  • Reinforce the Group’s expectations in relation to ethical conduct and supply chain responsibility

The training covers concerns relating to both Hargreaves’ own operations and its supply chains.

8. Objectives for the Financial Year Ending 31 May 2026

During the financial year ending 31 May 2026, Hargreaves will:

  • Continue to assess and identify modern slavery risks across the Group.
  • Continue to train employees and raise awareness of anti-slavery and human trafficking.
  • Review findings from internal audits and checks relating to the systems and processes introduced to reduce the risk of forced labour and human trafficking.
  • Measure and review the key performance indicators set out in this statement.
Approval

This statement was approved by the Board of Hargreaves Services plc on 23 September 2025.

Gordon Banham
Chief Executive Officer
Hargreaves Services plc

Appendix 1: List of Subsidiaries
Registered Offices
  • 14.1: West Terrace, Esh Winning, Durham, DH7 9PT
  • 14.4: Van Heetveldelei 178, 2100 Deurne, Antwerp, Belgium
  • 14.5: Suite 2, Park House, Earls Colne Business Park, Earls Colne, Colchester, Essex, England, CO6 2NS
  • 14.8: 3 Nobel Boulevard, Cape Gate NE3, Vanderbijlpark, Gauteng, 1900
  • 14.9: Lot 6.05, Level 6, 8 First Avenue, Bandar Utama, 47800 Petaling Jaya, Selangor Darul Ehsan, Malaysia
  • 14.10: Room 1117-8, 11th Floor, Tuen Mun Central Square, No. 22 Hoi Wing Road, Tuen Mun, New Territories, Hong Kong
UK Subsidiaries
Registered office 14.1
  • Hargreaves (UK) Services Limited
  • The Monckton Coke & Chemical Company Limited
  • Maltby Colliery Limited
  • HE Contracts Limited
  • Maxibrite Limited
  • RocPower Limited
  • OCCW (St Ninians) Limited
  • OCCW (Duncanziemere) Limited
  • OCCW (Chalmerston) Limited
  • OCCW (Netherton) Limited
  • OCCW (Damside) Limited
  • OCCW (Broken Cross) Limited
  • OCCW (House of Water) Limited
  • C. A. Blackwell (Contracts) Limited
  • Geofirma Soils Engineering Limited
  • Renaissance Land Regeneration Limited
  • Hargreaves Land (North) Limited
  • Hargreaves Land (South) Limited
  • SBU Limited
  • S&B Utilities Limited
  • Dalquhandy Windfarm SPV Limited
  • Broken Cross Energy SPV Limited
  • North Kyle Windfarm SPV Limited
  • Kennoxhead SPV Limited
  • Broken Cross Windfarm SPV Limited
  • Westfield EFW SPV Limited
  • Poniel Energy SPV Limited
  • Killoch Energy SPV Limited
  • Westfield Windfarm SPV Limited
  • Westfield Solar SPV Limited
  • Hargreaves Land Group Limited
  • Mcleod Construction Materials Ltd
  • Hargreaves LD Limited
  • Hargreaves Environmental Services Limited
  • Hargreaves (UK) Limited
  • Hargreaves Industrial Services Limited
  • Forward Sound Limited
  • Hargreaves Land Limited
  • H Technical Resources Limited
  • Hargreaves Maltby Limited
  • Hargreaves Property Ventures Limited
  • Hargreaves Services (Westfield) Limited
  • Hargreaves Services (Castlebridge) Limited
  • Hargreaves Services (Blindwells) Limited
  • Hargreaves Services Forestry Limited
  • C.A. Blackwell Group Limited
  • Hargreaves Pension Company Limited
  • Hargreaves Land Holdings Limited
  • Hargreaves Waste Management Services Limited
  • Hargreaves Zinc Processing Limited
Registered office 14.5
  • Blackwell Earthmoving Limited
Non-UK Subsidiaries
Registered office 14.4
  • Hargreaves Carbon Products NV
Registered office 14.8
  • Hargreaves Services South Africa (Pty) Ltd
Registered office 14.9
  • Hargreaves Industrial Services Sdn Bhd
Registered office 14.10
  • Hargreaves Industrial Services (HK) Limited
  • Access Services (HK) Limited
  • Hargreaves Power Services (HK) Limited
  • Hargreaves Services (HK) Limited