Steps for the prevention of modern slavery

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors and suppliers, and we updated our processes to include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude. We expect our suppliers to hold their own suppliers to the same requirements.

All employees and suppliers are required to comply with Blocktech MEP’s procedures to prevent modern slavery and to conduct business in a manner such that modern slavery is prevented.

While Blocktech MEP complies with the Modern Slavery Act 2015, it acknowledges that it does not control the conduct of those in our supply chains.

To underpin our compliance with practical steps, Blocktech MEP have implemented the following measures:

• conduct of periodic risk assessments to determine which parts of our business and which of our suppliers are most at risk of modern slavery so that efforts can and are, focused on those areas;

• engage with our suppliers both to convey to them our anti-slavery policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses;

• introduced supplier pre-screening (for example as part of our tender process) and self-reporting for our suppliers on safeguarding controls;

• introduced contractual provisions for our suppliers to confirm their adherence to this policy and accept our right to audit their activities and (where practicable) relationships, both routinely and at times of reasonable suspicion; and

• conducting a full compliance check on the contractors and the personal service companies (PSC) we engage.

Responsibility for the policy

Responsibility for the prevention of modern slavery rests with Blocktech MEP’s Directors and senior management. The board of directors of the Company has overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations.

Managers are responsible for ensuring that their staff understand and comply with this policy and are given routine training on it.

Actions to report modern slavery or human trafficking

Blocktech MEP carry out a “Whistleblowing Procedure” which is intended to provide guidance on how concerns can be communicated to the Company. Concerns about suspected modern slavery associated with the Company or our suppliers may be reported by employees in this manner. The Whistleblowing Procedure applies to all employees in which we advise employees to immediately raise any concerns with a Director of Blocktech MEP.

Concerns should be raised if any employee or relevant body:

• suspects a person acting on behalf of Blocktech MEP is seeking to exploit another in a way which could amount to modern slavery;

• suspects that a person acting on behalf of one of Blocktech MEP’s suppliers is seeking to exploit another in a way which could amount to modern slavery;

• has received an approach from a person acting on behalf of Blocktech MEP who has invited the participation in acts which could result in offences under the Modern Slavery Act 2015 being committed;

• has information which leads to the reasonable conclusion that a person acting on behalf of Blocktech MEP or any supplier is preparing to commit, is committing or has committed an act in contravention of the Modern Slavery Act 2015.

Reports are kept confidential except where Blocktech MEP is required to pass information to relevant authorities. Blocktech MEP ensures full compliance in working with the relevant authorities to assist in the prevention of Modern Slavery.

Safeguards

We 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 own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. The Company will accept and take seriously concerns communicated anonymously.

However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations.

Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against an employee making such claims or allegations.

Communication and awareness of this policy

We aim to communicate our zero-tolerance approach to modern slavery to all suppliers and contractors and business partners at the outset of our business relationship with them and to reinforce it as appropriate thereafter.

Review

This Modern Slavery Statement is reviewed by Blocktech MEP’s Directors on an annual basis and is updated annually in accordance with any amendments and additions to the Modern Slavery Act.

Signed by Kyle Pullar, Director

On behalf of Blocktech MEP Ltd and its subsidiaries