Modern

Slavery

MODERN SLAVERY POLICY STATEMENT

APC Civils Limited understands that Modern Slavery is a criminal offence under the Modern Slavery Act 2015 and can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common is the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. This Policy sets out the Company’s aim to prevent opportunities for modern slavery to occur within its business or supply chain. This Policy’s use of the term “modern slavery” has the meaning given in the Act.

APC Civils Limited has a zero-tolerance approach to modern slavery and the use of Child Labour and Forced Labour in the workplace and are committed to acting ethically and with integrity in all business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery or human trafficking is not taking place anywhere in our own business or of our suppliers of goods and services. We expect our suppliers to hold their own suppliers to the same standard.

We adhere to the requirements of the United Nations Convention on the Rights of the Child, United Nations Supplementary Convention on the Abolition of Slavery, the Slave Trade, and Institutions and Practices similar to Slavery (1956) and the United Nations International Covenant on Civil and Political Rights. We do not exploit children or others for our gain. We do not condone forced labour, including forced child labour, nor do we condone or permit or force children or others to work long hours in hazardous or abusive environments.

We recognise the right of the child to be protected from economic exploitation and from performing any work that is likely to be hazardous or to interfere with the child’s education or to be harmful to the child’s health or physical, mental, spiritual, moral or social development.

We also recognise the right of people not to be forced to work or carry out services against their will under the threat of some form of punishment.

This Policy applies to all persons working for APC Civils Limited in any capacity including employees at all levels, contractors, agency workers and external consultants or any suppliers to the Company.

This Policy will be reviewed annually as a minimum and amended as and when required.

SHANE CLARKE, MANAGING DIRECTOR – 02/01/2024

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