This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 and sets out the actions that EQB Group has taken to ensure that modern slavery and human trafficking are not taking place in our organisation or in our supply chains.

This statement applies to EQB Group and its subsidiaries, including EQB Construction, EQB Groundworks & Civils, EQB Plant, and MCK Brickwork.

This statement is for the financial year ending 2026.

 

EQB Group’s Organisational Structure, Business and Supply Chains

EQB Group is a construction contractor undertaking new build, refurbishment, groundworks, civil engineering, infrastructure and associated construction works across the United Kingdom.

EQB Group works with a range of clients, subcontractors, labour providers, recruitment agencies and suppliers. The Group recognises the importance of maintaining responsible and ethical supply chains.

Although our business activities are primarily carried out in the United Kingdom, we recognise that some suppliers may source materials, manufacture products or provide services through wider supply chains, including outside the UK.

EQB Group’s supply chains include:

• Sourcing of labour through subcontractors.
• Recruitment agencies and labour providers.
• Suppliers of goods, services and materials.
• Plant, equipment and machinery suppliers.
• Specialist trade contractors.
• Professional and support service providers.

 

Definitions

EQB Group considers that modern slavery encompasses:

• Human trafficking.
• Forced, bonded or compulsory labour.
• Servitude.
• Forced work through mental or physical threat.
• Being owned or controlled by an employer through mental or physical abuse, or the threat of abuse.
• Being dehumanised, treated as a commodity, or being bought or sold as property.
• Being physically constrained or having restrictions placed on freedom of movement.
• Illegal working and labour exploitation.

 

Potential Exposure

EQB Group considers its main exposure to the risk of slavery and human trafficking to exist within subcontracted labour, agency labour and the procurement of materials from suppliers whose wider supply chains may include higher-risk countries or sectors.

The Group seeks to work with reputable suppliers and subcontractors who are known to the organisation or who are subject to appropriate checks before appointment.

In general, EQB Group considers its exposure to slavery and human trafficking to be relatively limited. Nonetheless, the Group recognises that the construction sector can be exposed to modern slavery risks and has taken steps to ensure that such practices do not take place in its business or within the business of any organisation that supplies goods or services to the Group.

 

Commitment

EQB Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions of the Modern Slavery Act 2015. The Group understands that this requires ongoing review of both its internal practices in relation to its workforce and its supply chains.

EQB Group does not do business with any organisation, in the UK or elsewhere, that knowingly supports, facilitates or engages in slavery, servitude, forced labour or human trafficking.

No labour provided to EQB Group in the pursuance of its own services is obtained by means of slavery or human trafficking. EQB Group strictly adheres to the minimum standards required under relevant UK employment, immigration, health and safety and equality legislation.

It is the responsibility of all EQB Group personnel, particularly those involved in procurement, commercial management, recruitment, human resources, site management and supply chain engagement, to support the Group’s duties under the Modern Slavery Act 2015.

 

Illegal Working and Right to Work Checks

EQB Group is committed to ensuring that all employees and workers have the legal right to work in the United Kingdom.

The Group conducts appropriate Right to Work checks in accordance with applicable UK immigration legislation and Home Office guidance.

Where an individual is not a UK citizen, appropriate documentation or online status evidence will be requested and verified before employment begins.

Records of Right to Work checks are retained in accordance with legal requirements, and all personal data is handled in accordance with data protection legislation.

EQB Group also expects subcontractors, recruitment agencies and labour providers to carry out appropriate Right to Work checks for their own employees and workers.

 

Due Diligence

To ensure that slavery and human trafficking are not taking place within our business or supply chains, EQB Group shall:

• Ensure that employees are legally employed and have the right to work in the United Kingdom.
• Ensure that employees are paid in accordance with applicable wage legislation.
• Ensure that working conditions are safe and that working hours are not excessive.
• Expect subcontractors and labour providers to comply with their own staffing and employment obligations.
• Include appropriate pre-contract checks with new suppliers and subcontractors.
• Use supplier and subcontractor pre-qualification processes where appropriate.
• Maintain relationships with reputable suppliers and subcontractors.
• Communicate the Group’s expectations regarding ethical business conduct.
• Conduct supplier or subcontractor reviews, audits or spot checks where appropriate.
• Improve awareness amongst the workforce of the signs of modern slavery and the process for reporting suspected concerns.
• Protect whistle-blowers by providing a mechanism for employees, workers and others connected with the Group to raise concerns without fear of reprisals.
• Use the Procurement, Commercial, HR and Site Management teams to support supplier engagement and compliance.
• Publish this Modern Slavery and Human Trafficking Statement on the EQB Group website for public access.

 

Measuring Effectiveness

EQB Group uses the following measures to assess the effectiveness of its approach to ensuring that slavery and human trafficking are not taking place in any part of its business or supply chains.

EQB Group is committed to:

• Ensuring relevant employees receive appropriate training and awareness guidance on modern slavery.
• Maintaining supplier and subcontractor verification processes.
• Reviewing potential suppliers and subcontractors before they enter the supply chain.
• Periodically reviewing existing suppliers and subcontractors.
• Monitoring Right to Work compliance.
• Reviewing any whistleblowing reports or concerns relating to modern slavery, labour exploitation or illegal working.
• Reviewing and updating relevant policies and procedures where required.

 

Training

Relevant employees, particularly those engaged in recruitment, procurement, commercial management, site management and supply chain engagement, receive guidance and awareness training to support understanding of the risks associated with modern slavery within our operations and supply networks.

EQB Group includes modern slavery awareness within its employee induction process and provides guidance on the signs to look out for and the procedure for reporting concerns.

Employees responsible for recruitment, HR, health and safety, site management and onboarding are expected to remain vigilant for indicators of labour exploitation, fraudulent Right to Work documentation, coercion, intimidation or other warning signs of modern slavery.

All staff are informed of the Group’s Modern Slavery Policy, which is included in new employee inductions.

 

Related Policies

EQB Group has the following policies and procedures which further define and support its stance on modern slavery:

• Modern Slavery Policy.
• Corporate Social Responsibility Policy.
• Anti-Bribery and Corruption Policy.
• Whistleblowing Policy.
• Equal Opportunities Policy.
• Recruitment and Right to Work procedures.
• Procurement procedures.
• Health and Safety procedures.

These policies are available to employees through the company’s internal systems and employee documentation.

Approval

The EQB Group Board of Directors has approved this Modern Slavery and Human Trafficking Statement.

This statement will be reviewed annually or sooner where legislative, organisational or operational changes require it.

Date: 11/03/2026