Financial Year Ending April 2026
Signed by: Richard Chitty, CEO

1.0 Purpose

Modern slavery is a serious crime and a violation of fundamental human rights. It includes slavery, servitude, forced or compulsory labour and human trafficking. These practices involve the exploitation of individuals for personal or commercial gain.

Frankham Consultancy Group (“Frankham”) is committed to acting ethically and with integrity in all business dealings. Frankham adopts a proportionate and risk-based approach to modern slavery prevention, reflecting the nature, scale and complexity of its operations as a professional services consultancy.

2.0 Policy

Frankham has a zero-tolerance approach to modern slavery and human trafficking.

Frankham is committed to:

• Complying with all applicable legislation, including the Modern Slavery Act 2015.
• Acting with integrity in all business relationships.
• Taking reasonable and proportionate steps to identify, assess and reduce the risk of modern slavery within its operations and supply chain.

Maintaining transparency in accordance with statutory reporting obligations where applicable.

Although Frankham does not currently meet the turnover threshold requiring publication of a Modern Slavery Statement under Section 54 of the Modern Slavery Act 2015, the Company has elected to publish an annual Modern Slavery Statement on a voluntary basis.

Frankham’s approach is informed by the principles set out in the UN Guiding Principles on Business and Human Rights and relevant International Labour Organisation (ILO) conventions relating to forced labour.

Frankham recognises that modern slavery forms part of the broader category of human rights risks that may arise within business operations and supply chains. The Company is committed to conducting its activities in a manner consistent with internationally recognised human rights principles and expects the same standards from those with whom it works.

The Statement will be approved by the Board of Directors, signed by a Director and published on the Company’s website. This position will be reviewed annually.

3.0 Compliance with Law

The Company and its suppliers are expected to comply with all applicable national and local laws relating to employment, labour standards and human rights in the jurisdictions in which they operate. Where local law provides a lower standard than internationally recognised labour standards, the Company expects suppliers to operate to the higher standard wherever reasonably practicable.

4.0 Labour Standards

Frankham expects its employees, suppliers and business partners to uphold fundamental labour standards consistent with applicable law and internationally recognised human rights principles. These include:

• compliance with all applicable labour and employment laws
• freedom for workers to terminate employment in accordance with applicable contracts
• freedom of movement and retention of personal identity documents
• freedom of association and collective representation where permitted by law
• prohibition of child labour
• prohibition of forced or compulsory labour
• prohibition of recruitment fees charged to workers
• prohibition of discrimination, harassment or intimidation
• prohibition of confiscation of worker’s identity documents
• prohibition of compulsory overtime. Workers must not be required to work overtime against their will.  Overtime should be voluntary and comply with applicable laws and industry standards.
• access to grievance mechanisms and remediation where concerns arise.

The Company expects that all workers are treated with dignity and respect. Any form of violence, harassment, intimidation, abuse or inhumane treatment of workers is strictly prohibited within the Company’s operations and supply chains.

5.0 Scope/To Who This Policy Applies

This policy applies to:

• All employees
• Directors and officers
• Agency workers and secondees
• Consultants and subcontractors
• Suppliers and business partners working with or on behalf of Frankham

This policy does not form part of any contract of employment and may be amended as required.

6.0 Related Policies and Procedures

This policy should be read in conjunction with:

• Whistleblowing Policy
• Supplier Approval Process
• Health & Safety Policies
• Code of Conduct (where applicable)

7.0 Responsibility For The Policy

The Frankham Senior Management Team (SMT) has overall responsibility for ensuring this policy is implemented and reviewed.

The Group Commercial Director has primary responsibility for day‑to‑day oversight, monitoring effectiveness, responding to queries, reviewing supply chain arrangements and reporting significant concerns to the SMT

Managers at all levels are responsible for ensuring their teams understand, comply with and receive regular training on this policy and modern slavery risks.

8.0 Risk Assessment

Frankham undertakes a proportionate assessment of modern slavery risk, taking into account:

• The professional nature of its services
• Its UK-based operations
• Workforce profile
• Supply chain structure

Based on its assessment, Frankham considers the risk of modern slavery within its directly employed workforce to be low due to the nature of its professional services, UK employment contracts and right-to-work verification processes.

Potential areas of elevated risk may arise within parts of the wider supply chain that are common across the construction and built environment sector, including:

• construction contractors and labour-intensive subcontractors
• facilities management and site services providers
• cleaning, security and maintenance services
• suppliers operating through agency labour or labour providers

Frankham recognises that modern slavery risks can arise within supply chains. As part of its Supplier Approval Process, Frankham seeks to verify supplier legitimacy, legal status and professional competence. Where a supplier operates in sectors or geographies identified as presenting elevated risk, additional enquiries may be undertaken as considered proportionate.

Frankham recognises that procurement practices can influence labour conditions within supply chains. The Company seeks to maintain responsible procurement practices, including fair commercial arrangements and reasonable delivery expectations, to avoid creating pressures that could increase the risk of labour exploitation.

This risk position is reviewed at least annually as part of Frankham’s Integrated Management System review cycle.

9.0 Supply Chain Overview

Frankham’s supply chain primarily consists of:

• professional consultancy subcontractors (engineering, surveying, specialist advisors)
• construction contractors engaged on small opening up works to facilitate the performance of our professional services
• professional service providers
• operational support services (IT, facilities management and office services).

The majority of suppliers operate within the United Kingdom and are engaged through formal contractual arrangements.

As part of its Supplier Approval Process, Frankham undertakes proportionate checks on suppliers including verification of legal status, professional competence, relevant insurances and applicable policies.

10.0 Supply Chain Approach

Frankham expects its suppliers and subcontractors to comply with all applicable laws relating to modern slavery and human trafficking, including the Modern Slavery Act 2015 where applicable.

Through its standard terms and conditions and supplier approval processes, Frankham requires compliance with applicable statutory requirements and employment legislation.

This policy is made available to suppliers and relevant business partners as part of the Company’s supplier onboarding and contractual arrangements. Suppliers are expected to communicate appropriate labour standards to their own workforce and subcontractors where relevant.

Where suppliers have been classified as higher risk or contractors (opening up), Frankham requires suppliers to confirm compliance with modern slavery legislation and the principles of this policy as part of contractual terms or supplier onboarding processes.

Where the Company identifies suppliers operating in sectors or locations presenting a higher risk of modern slavery, the Company may provide or require appropriate awareness information regarding modern slavery risks and expectations.

Regardless of supplier categorisation, where concerns are raised, Frankham reserves the right to investigate and to exercise its contractual rights, including termination where appropriate.

Modern slavery considerations form part of Frankham’s broader supplier approval and procurement processes within its Integrated Management System.  Frankham’s approach is proportionate to the nature and scale of its professional services business.

11.0 Access to Remedy and Compensation

Where instances of modern slavery or labour exploitation are identified, the Company will work with relevant stakeholders, including suppliers and appropriate authorities, to ensure that affected individuals have access to appropriate remedy, support and, where applicable, compensation in accordance with applicable laws.

12.0 Key Performance Indicators

Monitoring Effectiveness: Frankham monitors the effectiveness of its modern slavery controls through a number of internal indicators, including:

• proportion of suppliers risk assessed annually through the Supplier Approval Process
• number of modern slavery concerns raised through whistleblowing or reporting mechanisms
• number of high risk and contractor (opening up) suppliers who have had an annual periodic review of modern slavery compliance documentation
• proportion of employees who have received modern slavery awareness training (refresher and/or induction)

These indicators are reviewed at least annually by senior management as part of the Integrated Management System review cycle.

13.0 Communication & Awareness

This policy is:

• Communicated to employees
• Available on shared systems
• Referenced during induction

Given the nature of Frankham’s operations and current risk profile, formal role-specific modern slavery training programmes are not currently considered necessary. Awareness is maintained through management oversight and policy accessibility.

This position is reviewed periodically as part of the Integrated Management System.

14.0 Reporting Concerns

Employees and associated persons are encouraged to report any concerns regarding modern slavery or unethical practices.

Reports may be made to:

• Line management
• The Group Commercial Director
• In accordance with the Whistleblowing Policy

Where a potential instance of modern slavery is identified, Frankham will assess the circumstances and determine an appropriate response which may include:

• investigation of the concern
• engagement with the relevant supplier or organisation
• escalation to senior management
• referral to appropriate authorities or support mechanisms where required.

Frankham will not tolerate detrimental treatment against individuals who raise concerns in good faith.

The intention is to encourage improvement rather than penalise, and we hope that most problems can be settled informally.

We have set up a dedicated Survey Monkey link.

For staff who wish to report concerns of Modern Slavery, anonymously.

Where appropriate, Frankham may refer potential victims to relevant authorities or support mechanisms, including the National Referral Mechanism.

15.0 Breaches

Any employee found to be in breach of this policy may face disciplinary action.

Where a supplier or subcontractor is found to have breached applicable laws or contractual obligations relating to modern slavery, Frankham may take appropriate contractual action in accordance with its existing contractual rights.

16.0 General Indicators of Modern Slavery

Indicators may include:

• Inability to leave work or living conditions
• Signs of control, coercion or fear
• Lack of access to identification documents
• Excessive working hours
• No direct access to wages
• Debt bondage
• Poor living conditions

Not all indicators will be present in every situation. Concerns should be reported in accordance with Section 9 of this policy.

17.0 Continuous Improvement

Frankham is committed to the continuous improvement of its systems and controls designed to identify and address modern slavery risks within its operations and supply chains.