Modern Slavery & Human Trafficking Statement

MSS Infrastructure Ltd
Modern Slavery & Human Trafficking Statement
Issue 13
Review Date: 01/07/2027

Publication Date: 01/07/2026

Introduction

This statement sets out the Company’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities undertaken during the financial year ending 31 December 2025.

As a supplier of labour to the construction and infrastructure sectors, MSSI recognises that these industries can present an increased risk of labour exploitation and modern slavery and is therefore committed to maintaining robust controls to prevent such practices.

The Company is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

The Company has a commitment to legal compliance, ethical standards and fundamental human rights as set out by the principles of the ILO/UN Guiding Principles.

Organisational Structure and Supply Chains

This statement covers the activities of MSSI. The Company is one of the UK’s largest specialist recruitment agencies providing the Infrastructure sector of the Construction industry with permanent, contract and temporary staff at all levels. Consulting and recruiting for nearly four decades, we can supply staff, labour and support services to civil engineering contractors, sub-contractors, utilities, infrastructure owners and operators nationally.

In our work as a Construction recruitment agency, we support both those looking to recruit staff and those looking for Construction jobs. We ensure that the staff we provide have the necessary skills and safety knowledge to do the job to an excellent standard in the markets we specialise in, as well as following UK industry standards, we comply with the law as a minimum.

The Company has an annual turnover in excess of £67m.

MSSI is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Ethical Trading Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Modern Slavery Risks and Risk Management

As a supplier of temporary, contract and permanent labour to the construction and infrastructure sectors, MSSI recognises that certain aspects of its business and supply chain may present an increased risk of modern slavery, forced labour, labour exploitation and human trafficking.

The areas identified as presenting the highest risk are:

Temporary labour supply to construction and infrastructure projects.
Use of migrant workers and workers whose first language is not English.
Third-party labour providers and recruitment partners.
Umbrella companies and payroll intermediaries.
Workers who may be vulnerable due to financial hardship, lack of awareness of employment rights or personal circumstances.

To assess and manage these risks, MSSI:

Conducts right-to-work checks for all workers prior to engagement.
Verifies worker identity documentation in accordance with legal and client requirements.
Carries out due diligence on labour providers, suppliers and business partners before engagement.
Maintains approved supplier processes and periodic supplier reviews.
Provides workers with clear information regarding pay, terms of engagement and reporting mechanisms.
Operates whistleblowing arrangements and encourages the reporting of concerns.
Investigates any allegations or indicators of worker exploitation or unethical labour practices.
Delivers modern slavery awareness training to relevant employees and managers.

MSSI adopts a zero-tolerance approach to modern slavery and continually reviews its controls to ensure risks are identified and mitigated.

Countries of Operation and Supply

We currently operate in the United Kingdom only.

The following is the process by which the Company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking.

The Supply chain is categorised according to an internal risks profile - these are:

Category	Description	Controls
Low Risk	UK-based suppliers providing office, professional or business support services with limited labour exploitation exposure.	Supplier approval and periodic review.
Medium Risk	Suppliers providing operational services, training, welfare facilities, PPE, transport or other support services involving significant labour resources.	Due diligence and supplier review.
High Risk	Labour providers, payroll intermediaries, umbrella companies, subcontract recruitment businesses and any supplier providing workers into the construction and infrastructure sectors.	Enhanced due diligence, verification of compliance with employment legislation, ongoing monitoring and audits where appropriate.
High Risk (Worker Vulnerability)	Temporary workers, migrant workers, workers with limited English language skills or workers considered vulnerable to exploitation.	Right-to-work verification, identity checks, worker engagement, whistleblowing arrangements and management oversight.

MSSI recognises that the greatest risk of modern slavery within its business arises through the supply of temporary labour and the engagement of third-party labour providers. These risks are managed through robust worker verification processes, supplier due diligence, right-to-work checks, staff training, whistleblowing arrangements and ongoing monitoring of labour supply chains.

Responsibility

Responsibility for the Company's anti-slavery initiatives is as follows:

Policies: The Head of Business Assurance & Compliance is responsible for putting in place and reviewing policies and the process by which they were developed
Risk Assessments: The Approved Suppliers list is reviewed to ensure the information is current. The regular suppliers are checked and are scheduled on the Management Review meetings to ensure continued compliance with required standards. Where possible we build long standing relationships with suppliers and make clear our expectations of business behaviour
Investigations/Due Diligence: The OHSE Director and Head of Business Assurance & Compliance are responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking
Training: To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All Directors/Managers have been briefed on the subject

Relevant Policies

The Company operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Modern Slavery Whistleblowing Policy: The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The policy is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use our confidential helpline
The Code of Ethics/Ethical Trading Policy: The Company’s Code of Ethics makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when operating and managing its supply chain
Sustainable Procurement Policy: The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the Company's supplier code of conduct will lead to the termination of the business relationship
Recruitment Policy: The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency

Due Diligence

MSSI considers the supply of temporary labour, the engagement of third-party labour providers, umbrella companies and vulnerable workers to represent the areas of highest modern slavery risk within its business and supply chain. Accordingly, enhanced due diligence and monitoring arrangements are applied to these areas.

The Company undertakes due diligence when considering taking on new suppliers and labour providers and regularly reviews its existing suppliers and business partners. The Company's due diligence and review processes include:

Mapping the supply chain to assess areas of potential modern slavery and human trafficking risk
Evaluating the modern slavery and human trafficking risks associated with each new supplier, labour provider or business partner prior to engagement
Verifying workers' identity and right to work in the United Kingdom before deployment
Assessing labour providers, recruitment partners and umbrella companies for compliance with employment legislation and ethical recruitment practices
Reviewing all aspects of the supply chain on a regular basis based on identified risk levels
Conducting supplier audits or assessments where a heightened risk of labour exploitation, slavery or human trafficking has been identified
Creating and maintaining risk profiles for suppliers and labour providers
Monitoring and investigating reports, allegations or indicators of worker exploitation and taking appropriate action where concerns are identified
Taking steps to improve supplier performance where standards fall below expectations
Monitoring industry best practice and guidance aimed at preventing modern slavery and labour exploitation
Invoking sanctions against suppliers, labour providers or business partners that fail to improve their performance or are found to have seriously breached our Ethical Trading Policy, including termination of the business relationship where appropriate

Performance Indicators

The Company continually reviews the effectiveness of its measures to prevent modern slavery and human trafficking within its business and supply chains.

To assess the effectiveness of these controls, MSSI monitors the following key performance indicators (KPIs):

Completion of right-to-work checks prior to worker engagement
Completion of identity verification checks prior to deployment
Percentage of employees completing annual modern slavery awareness training
Number of modern slavery concerns, allegations or reports received and investigated
Number of supplier and labour provider reviews completed
Number of supplier audits or compliance assessments undertaken where appropriate
Number of substantiated modern slavery incidents identified within the business or supply chain
Percentage of new suppliers and labour providers subject to modern slavery and compliance due diligence prior to approval

During the reporting period, MSSI:

Continued to undertake right-to-work and identity verification checks for workers prior to engagement
Maintained its supplier approval and review processes
Delivered annual modern slavery awareness training to relevant employees
Investigated any reported concerns in accordance with company procedures
Identified no substantiated instances of modern slavery or human trafficking within its business operations

MSSI reviews these indicators annually to identify opportunities for continuous improvement and to ensure the effectiveness of its anti-slavery and human trafficking controls.

Training

MSSI recognises that training and awareness are essential in preventing modern slavery and human trafficking.

All employees receive modern slavery awareness training as part of their induction programme and undertake refresher training annually thereafter. Additional training is provided to employees involved in recruitment, compliance, supplier management and operational management activities where there is an increased risk of exposure to labour exploitation indicators.

The Company's modern slavery training covers:

How to identify the signs of modern slavery, forced labour and human trafficking
How to assess the risk of slavery and human trafficking within our business and supply chains
What action should be taken if slavery or human trafficking is suspected
How to report concerns and escalate issues internally
The Company's whistleblowing arrangements and worker reporting mechanisms
External support available through organisations such as the Modern Slavery Helpline and Stronger Together
The role employees play in ensuring compliance with the Modern Slavery Act 2015
Expectations placed upon suppliers, labour providers and business partners regarding ethical recruitment and labour practices

Awareness-Raising Programme

As well as training staff, the Company has raised awareness of modern slavery issues by circulating a series of emails to staff.

The emails explain to staff:

the basic principles of the Modern Slavery Act 2015
how employers can identify and prevent slavery and human trafficking
what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the Company
what external help is available, for example through the Modern Slavery Helpline

Board Approval

This statement has been approved by the Executive Board Committee, who will review and update it annually.