Modern Slavery Statement

This statement has been published in accordance with Section 54 of the UK Modern Slavery Act (2015). It sets out the steps taken by Ringway Jacobs Limited to prevent modern slavery and human trafficking within our business and supply chain during year ending 31st December 2024. Our next statement will be published in January 2025.

Ringway Jacobs Limited is a leading highways service provider working with local authorities across the UK, with an annual turnover in the region of £207million. We currently operate in Cheshire East and Essex.

Ringway Jacobs Limited has a Code of Conduct and Ethics and the principles of this code are reflected within this statement.

Our Modern Slavery and Human Trafficking policy continues to be communicated to our employees and our supply chain and is embedded into the way we work.

During 2022 we re-launched a bespoke Modern Slavery eLearning programme to ensure that all staff and suppliers fully understand the risks of modern slavery.

Our supply chain comprises subcontractors of all sizes that provide specialist services. Subcontracted works account for approximately 40% of our turnover with further services being delivered directly by in house teams/Shareholders, with materials being sourced from external suppliers/manufacturers. Over a year we may contract with around 250 subcontractors across the UK. Our supply chain is integral to our operations and our success and reputation is inextricably linked to their performance and ethical standards.

Our overarching supply chain strategy is to build long-term relationships with a consolidated number of high performing subcontractors and suppliers.

Ringway Jacobs Limited operates to a company-wide set of policies and procedures that govern the way we engage with our supply chain, in a fair manner, paying promptly and developing relationships with companies that work safely, provide good quality and embrace our ethical standards.

Our policies explicitly state how we operate as a business and the steps we take to ensure that we are a transparent, accessible and inclusive organisation. These policies are reviewed regularly and updated to ensure that ongoing opportunities for improvement are identified and acted upon. These policies are available for viewing by all Ringway Jacobs Limited personnel via our internal policy portal and include:

• Code of Conduct and Ethics
• Social Value
• Anti-Bullying and Harassment
• Anti-Bribery
• Equality and Diversity
• Recruitment and Selection
• Modern Slavery and Human Trafficking
• Whistleblowing
• Procurement Policy

Employees must ensure that they read and comply with these policies and understand that the prevention and reporting of modern slavery in any part of the business and supply chain is the responsibility of all those working directly for Ringway Jacobs and those under its control.

Ringway Jacobs Limited acknowledges that the construction sector can be particularly vulnerable to targeting by those responsible for slavery and trafficking. Construction is labour intensive, often working to tight commercial margins and works may well be spread across numerous subcontractors who themselves may on occasion sub-subcontract. We focus strongly on not only developing robust policies but also enforcing them and educating our direct and subcontract workforces.

Our whistleblowing policy applies to all employees of Ringway Jacobs. Other individuals performing functions in relation to the organisation, such as agency workers and contractors, are also encouraged to use it. This allows safe reporting by any individual of any wrongdoing including human rights abuses either being directly experienced or witnessed. Individuals are encouraged to raise such concerns with their line managers but are free to contact Safecall, a third-party whistleblowing helpline, should they prefer.

Our workforce

In respect of our contingent labour and resource processes, we work with a number of preferred suppliers, to fulfil our contingent workforce requirements.

For permanent staff we have implemented a commercial agreement with a recruitment process outsourcing provider to standardise our legislative approach to recruitment across our businesses. This includes carrying out right to work and pre-employment checks on all employees joining our organisation ensuring that the employee can provide evidence that they are in possession of their own identification documents and that the bank account details provided belong to them and not a third party. Any discrepancies identified are investigated thoroughly and appropriate action taken. We undertake annual reviews with these partners.

Employees undertake a modern slavery awareness module as part of their induction into the organisation and on an annual basis thereafter. Line managers receive Equality Act training.

Our Supply Chain

Before undertaking works for Ringway Jacobs, our prequalification process in Tradex (our Supply Chain onboarding platform), requires Subcontractors and Suppliers applying to work for us to provide satisfactory answers to specific questions relating to modern slavery, equality, diversity and inclusion, social values and the Bribery Act. Our approvers receive guidance on how to appropriately manage poor responses from onboarding Suppliers.

As part of strategy and policy in relation to modern slavery, we will continue to take the following steps:

• As a member of the Supply Chain Sustainability School, we will utilise their online learning resources to further enhance the education of our subcontractors' staff on modern slavery and human trafficking issues.
• Identify and deliver more specific extra training for our supervisors and managers who regularly interface with subcontractors on site, to highlight warning signs relating to modern slavery and human trafficking.
• Conduct supply chain forums on a Contract-by-Contract basis which include sessions on modern slavery and trafficking as well as fairness, inclusion and respect.
• Employ additional methods such as distributing and displaying multilingual posters and post cards in our workplaces to raise awareness of modern slavery, including how to find more information and report slavery.
• Implement a Supply Chain Code of Conduct
• Continue to roll out e-learning modules on Modern Slavery to staff and suppliers.

Having reviewed the original strategy in conjunction with our own 2024 Business Plan targets, the following deliverables have been identified for the coming 12 to 18 months: -

• Having identified potentially higher risk areas within our supply chain for suppliers we will agree an action plan to further investigate risk levels and mitigations.
• Revisit supply only and subcontract terms and conditions to reinforce our supply chains' responsibility to reduce the likelihood of modern slavery within their organisations and supply chains.
• Hosting two supply chain partner senior management days per year, led by the Ringway Jacobs Managing Director to include sessions on modern slavery and trafficking as well as fairness, inclusion and respect.
• Undertake a twice-yearly Management Board review of the risk to the organisation posed by modern slavery.

Signed

Philip Horton, Managing Director, Ringway Jacobs Limited

30 April 2024