Modern Slavery and Human Trafficking Statement

Introduction

This Modern Slavery and Human Trafficking Statement is made on behalf of The Gelder Group and sets out the steps taken to prevent modern slavery and human trafficking within its business operations and supply chains.

The Gelder Group is committed to acting ethically and with integrity in all business relationships and to implementing effective systems and controls to mitigate the risk of modern slavery. As part of the industry in which it operates, the organisation recognises that it has a responsibility to take a robust approach to modern slavery and human trafficking.

In line with the requirements of Section 54 of the Modern Slavery Act 2015, this Statement demonstrates the organisation’s commitment to responsible business practices and to meeting the expectations of clients, stakeholders and partners.

Organisational Structure and Supply Chains

The Gelder Group is a nationally trading construction company based in Lincolnshire, England. This statement covers the activities of The Gelder Group, including:

• Gelder Group Holdings
• Gelder Ltd
• Xeric
• Dewpoint
• Redline
• LoveDIY
• Gelder Homes (Ingham) Ltd
• Gelder Investments Ltd
• Design Space Architecture Ltd
• Gainsborough Home Improvements Ltd

Governance

The Gelder Group has a zero-tolerance approach to modern slavery and human trafficking. This commitment is embedded into the organisation’s governance arrangements and reflected in its expectations of employees, workers, suppliers and business partners.

Responsibility for the organisation’s anti-slavery and human trafficking initiatives is as follows:

Policies

The Senior Management Team maintains oversight of modern slavery risks and ensures that appropriate policies, procedures and controls are in place to support ethical working practices.

Designed by the Senior Management Team in conjunction with The Gelder Group’s HR Consultant, Beststart Human Resources, the company policies contained within the handbook are reviewed annually, or more frequently in the event that new legislation is passed which might affect the company’s activities or policies.

The Gelder Group expects all individuals working for or on its behalf to act responsibly and in a manner consistent with the organisation’s values.

Risk Assessments

The Gelder Group undertakes proportionate risk assessments to identify areas where there is a potential risk of modern slavery. The organisation considers the nature of its activities, the sectors in which it operates, geographic factors and the characteristics of its supply chain.

Based on these assessments, The Gelder Group considers the risk of modern slavery occurring within its direct operations to be low, given the UK-based nature of its workforce and activities.

The organisation, however, recognises that risks may arise within supply chains and remains alert to potential indicators of exploitation when engaging third-party suppliers.

Investigations and Due Diligence

The Gelder Group applies reasonable and proportionate due diligence when engaging new suppliers and business partners. This includes considering the nature of the goods or services provided, the supplier’s location and the manner in which workers are recruited, engaged and treated.

Where potential risks or concerns are identified, The Gelder Group will seek appropriate assurances and may require corrective action. The organisation reserves the right to review, suspend or terminate business relationships where serious or persistent modern slavery concerns are identified and not adequately addressed.

Education and Awareness

The Gelder Group provides guidance and information to ensure that relevant employees understand what modern slavery and human trafficking are, how they may present and the role individuals play in preventing exploitation. Training and awareness activity is intended to equip individuals with the knowledge required to identify warning signs and to respond appropriately.

The organisation promotes a culture in which ethical behaviour and vigilance are encouraged and supported.

As part of this awareness training, the Home Office-published Modern Slavery Awareness Booklet is made available to all employees.

Relevant Policies

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

Whistleblowing Policy

The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains, of the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures without fear of retaliation. For full details, see the Whistleblowing Policy and Procedure in the organisation’s Staff Handbook.

Employee Code of Conduct

The organisation’s Code of Conduct makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating within the United Kingdom and abroad and when managing its supply chain.

Procurement Code of Conduct

The organisation 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 organisation works with suppliers to ensure that they meet the standards of the code and improve their workers’ working conditions. However, serious violations of the organisation’s supplier Code of Conduct will lead to the termination of the business relationship.

The organisation’s due diligence and reviews will evaluate the modern slavery and human trafficking risks of each new supplier by:

• Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking, and regularly reviewing all aspects of the supply chain based on the supply-chain mapping.
• Conducting supplier audits or assessments with a greater degree of focus on slavery and human trafficking where general risks are identified.
• Creating an annual risk profile for each supplier.
• Taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans.
• Participating in collaborative initiatives focused on human rights in general and slavery and human trafficking in particular.
• Invoking sanctions against suppliers that fail to improve their performance, up to and including the termination of the business relationship.

Investigations and Corrective Action

The Gelder Group will investigate allegations or suspicions of modern slavery promptly and objectively and, where appropriate, steps will be taken to safeguard affected individuals and to engage with relevant authorities or specialist bodies.

Where modern slavery risks are identified, the organisation will take all corrective action within its control to address the issue and to strengthen controls, systems or processes to prevent recurrence.

Breaches of expected standards may result in disciplinary action or the termination of contractual arrangements.

Monitoring and Review

The Gelder Group will monitor and review its approach to preventing modern slavery to ensure that controls remain effective and proportionate to the size, nature and risk profile of the business. Oversight is maintained through management review and continuous consideration of emerging risks and best practice.

The organisation is committed to continuous improvement and will enhance its approach to modern slavery prevention as its business activities, supply chains or risk exposure evolve.

As part of The Gelder Group’s commitment to this Statement, we will measure its effectiveness against the following performance indicators:

• Percentage completion rates for modern slavery awareness training.
• Percentage of employees and supply-chain partners assessed for modern slavery risks.
• Compliance with our supply-chain approval and due-diligence procedures.
• The number of concerns reported, investigated and resolved.
• Percentage of corrective actions identified and completed following audits or reviews.
• Annual review and approval of the statement by senior management.

—
Steve Gelder
Chief Executive Officer

Document date: 2^nd October 2025.