strukta Group Limited Modern Day Slavery Policy

Modern Day Slavery Policy

This statement sets out strukta Group’s actions to understand all potential modern slavery risks related to its business and to put in place steps 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 during the financial year from 1 January 2026 to 31 December 2026.

As part of the construction industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.

Our organisation 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.

Organisational Structure and Supply Chains

This statement covers the activities of strukta Group.

strukta are recognised in the construction sector as Specialist Builders Merchants, providing an unparalleled service and distributing products to a strong, loyal, and growing customer base.

Countries of Operation and Supply

We currently operate in the following countries:

• The United Kingdom

The following process is used to assess whether particular activities or countries are high risk in relation to slavery or human trafficking:

• Supply chain risk assessment process in relation to country operations and slavery and human trafficking

Responsibility

Responsibility for our anti-slavery initiatives is as follows:

• Policies: The Managing Director of strukta Group Ltd, Mr Adrian Diffey, is responsible for putting in place and reviewing policies with the assistance of department managers and external consultants to ensure that there is no slavery or human trafficking within the organisation and its supply chain.
• Risk assessments: Conducted to identify risks and communicated to relevant parties.
• Investigations and due diligence: The Strategic Sourcing Manager conducts due diligence in relation to known or suspected instances of slavery and human trafficking. Where instances are identified, efforts are made to address them and contracts may be terminated.
• Training: Modern slavery training is provided internally. Annual surveys are sent to suppliers to ensure that they are providing training to their staff to identify the risk of modern slavery.

Policies

We operate the following policies which describe our approach to identifying modern slavery risks and the steps taken to prevent slavery and human trafficking:

• Whistleblowing Policy: We encourage workers, customers and business partners to report concerns related to our activities or supply chains, including risks of slavery or human trafficking. Reports can be made without fear of retaliation. Concerns may also be raised with Public Concern at Work on 020 7404 6609.
• Employee Code of Conduct: This code sets out the actions and behaviour expected of employees. We maintain high standards of conduct and ethical behaviour in all operations and supply chain management.
• Supplier and Procurement Code of Conduct: Suppliers must demonstrate safe working conditions, treat workers with dignity and respect, and comply with the law. Serious violations will lead to termination of the business relationship.

We undertake due diligence when taking on new suppliers and when reviewing existing suppliers. This includes:

• Mapping supply chains to assess product and geographical risks
• Evaluating modern slavery and human trafficking risks of new suppliers
• Regular reviews of the entire supply chain
• Conducting supplier audits where higher risks are identified
• Creating an annual risk profile for each supplier
• Supporting suppliers to improve substandard practices
• Participating in collaborative initiatives focused on human rights and slavery prevention
• Invoking sanctions or terminating relationships for serious or unresolved violations

Performance Indicators

We have reviewed our key performance indicators and are:

• Requiring all staff to complete modern slavery training
• Developing a supply chain verification system for new suppliers
• Reviewing all existing suppliers through audits and assessments

Training

All staff are required to complete modern slavery training. The training covers:

• Responsible purchasing practices and fair labour standards
• Assessing and identifying slavery and human trafficking risks
• Recognising signs of slavery and human trafficking
• Steps to take if modern slavery is suspected
• Escalation procedures within the organisation
• External support such as the Modern Slavery Helpline and relevant authorities
• Guidance for suppliers to implement anti-slavery policies
• Actions taken where suppliers fail to meet required standards

Senior Leadership Team Approval

This statement was approved on 7 April 2026 by the Senior Leadership Team and is reviewed and updated annually.