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Modern Slavery Act

Duerden Group is committed to preventing modern slavery and human trafficking across our operations and supply chains. Modern slavery is a serious crime and a violation of fundamental human rights. We are dedicated to ensuring that our business and those who work with us uphold the highest standards of ethics and integrity, and that our supply chains are free from any form of exploitation.
We conduct our business in a responsible manner and strive to respect, support, and protect human rights by seeking to:
  • Eliminate discrimination in employment
  • Prohibit all forms of modern slavery, including child and forced labour
  • Eradicate harassment and physical or mental abuse in the workplace

Scope

The UK Modern Slavery Act 2015 (“MSA UK”) requires certain organisations to set out the steps they take to identify and mitigate the risks of slavery and human trafficking in their business and supply chains. This Statement is made in accordance with the MSA UK and relates to the period 1 January 2025 to 31 December 2025.
This Statement has been prepared and approved by the Board of Directors of Duerden Group.
We recognise that modern slavery and human trafficking risks are complex and evolving. We continue to assess and address these risks in our operations and supply chains. Our approach and processes are reviewed periodically and updated as necessary to reflect changes in our business, legal requirements, and good practice.

Our Business Activities

Assessing Modern Slavery Risk

Our approach is proportionate to the risks we face. We identify where risks may arise, apply due diligence to higher-risk areas, and review controls periodically.

Modern Slavery Risk Profile

1) Third-Party Vendors

Given the nature of our business and where we operate, our third-party suppliers generally fall into the following categories:
  • Outsourced services: business activities or professional services provided by external organisations.
  • Software and technology providers: including off-the-shelf tools and any associated hardware required for business processes.
  • Cloud/hosted IT services: infrastructure and platform services delivered in hosted environments.
  • Professional services: consultancy, legal, accounting, audit, banking, training and related services.
  • Data and information services: organisations providing data or information used in our systems and reporting.
  • Facilities and office services: building maintenance and repairs, cleaning, security, utilities and general office supplies.
Based on these categories and the regulated nature and professional skill levels typically involved, we assess the overall risk of modern slavery among these suppliers as low. We acknowledge some categories—such as multi-tier goods (e.g., office supplies) and certain facilities services—carry higher inherent risk. Each supplier has its own supply chain, and our assessments consider this to the extent possible; however, visibility into deeper tiers (tier-2/3) can be limited.

2) Employees

Our people drive our success. All Duerden Group employees are based in the UK, with the majority in professional and administrative roles. We maintain policies, procedures and processes designed to protect our workforce from modern slavery and human trafficking, including:
  • Fair employment terms and conditions
  • Clear processes for reporting and resolving concerns and grievances
  • Non-discriminatory recruitment and equal-opportunity practices
  • Right-to-work and employment-screening checks
  • Standards for appropriate workplace behaviour
Through our Positive Work Environment Policy, all employees are responsible for helping to maintain a respectful workplace and for reporting discrimination, harassment or abusive behaviour. Employees receive onboarding training on relevant policies and periodic refreshers, including attestations where appropriate.
We also maintain confidential reporting channels (whistleblowing) for employees, contractors, suppliers and other stakeholders to raise concerns about unethical, illegal, unsafe or otherwise unacceptable conduct, including potential modern slavery. Reports are reviewed promptly and handled sensitively, and we do not tolerate retaliation against anyone who raises a concern in good faith.
Based on the above, we consider the risk of modern slavery within our UK employee population to be low.

Management of Modern Slavery Risks

1) Governance

We recognise that strong governance underpins sustainable operations. Our approach to modern slavery risk is proportionate and aligned to legal and ethical standards. Key supporting policies and guidelines include (together, the “Policy Framework”):
  • Anti-Slavery and Human Trafficking Policy – procedures to identify, assess and mitigate modern slavery risks in our operations and supply chains, including training and risk assessments.
  • Code of Business Conduct and Ethics – our commitment to ethical conduct and respect for human rights; employees provide periodic attestations.
  • Financial Crime Policies – anti-bribery, corruption and anti-money laundering controls that help prevent activity linked to criminal exploitation.
  • Positive Work Environment Policy – commitment to a workplace free from discrimination, violence and harassment, with clear reporting routes.
  • Whistleblowing Policy – confidential channels to raise concerns, expectations and responsibilities, protections against retaliation, and guidance on remediation and external disclosures.
Our Policy Framework is reviewed periodically and updated as necessary.

2) Training

All employees receive modern-slavery awareness during onboarding, with refresher guidance provided where appropriate. Training covers recognising indicators of exploitation, how to escalate concerns, and use of reporting channels.

3) Risk Assessment

We apply an annual, risk-based assessment of modern slavery exposure across our operations and supply chains. Supplier and category risk (including geography, service type and multi-tier depth) informs onboarding checks, contractual expectations, and ongoing monitoring.

4) Remediation

If concerns are identified, we seek to use our influence to drive corrective action with relevant parties. Where remediation is not possible or risks remain unacceptably high, we may suspend or terminate relationships in line with contractual and legal obligations.

5) Whistleblowing Hotline

As detailed above, the Hotline is available for employees, Vendors and other parties to anonymously report modern slavery and human trafficking issues among other things.

6) Measuring Effectiveness

As detailed above, the Hotline is available for employees, Vendors and other parties to anonymously report modern slavery and human trafficking issues among other things.
  • Tracking, investigating and resolving concerns raised via whistleblowing channels
  • Periodic reviews of higher-risk supplier categories and follow-up actions
  • Policy attestations and training completion rates
  • Ongoing refinement of supplier due-diligence and contract controls
  • Reporting of key risks and mitigation activities to senior leadership and the Board

Review and Approval

We will review this Modern Slavery Statement annually and update it as necessary. We will also ensure it remains easily accessible to anyone who wishes to read it. This Statement has been approved by the Board of Directors on behalf of Duerden Group and is made pursuant to section 54(1) of the Modern Slavery Act 2015.
Last updated: 7th October 2025