Enigma Industrial Services Ltd Modern Slavery statement

Introduction
This statement sets out Enigma Industrial Services Ltd 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. As part of the Enigma Industrial Services Ltd, the Company recognises it has a responsibility to take a robust approach to slavery and human trafficking. The Company is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring its supply chains are free from slavery and human trafficking.

1. We have a workforce of 850 in the UK delivering services covering a range of sectors, worldwide. In addition to our directly employed workforce there are many people employed in our supply chain.
2. Our values and our culture guide us to operate ethically and transparently. Consequently we are committed to ensuring that Modern Slavery1 does not exist in our workforce or our supply chain.
3. This statement should be read in conjunction with our Human Rights policy, business practices policy and with the policies and the supplier codes of conduct of our operating companies which state our position on human rights and the ethical standards we set for our own business activities and expect of our supply chain.
4. Our whistle blowing policy and procedures provide clear guidance for our own employees and those employed in our supply chain on what to do should they suspect modern slavery is taking place.
5. The main Modern Slavery risk within our subsidiaries’ operations stems from bringing workers employed by other companies on to our own or our customers’ sites, particularly agency workers. There are also potential risks in our supply chain in relation to goods and services at tiers one and below. Our suppliers and sub-contractors are required to comply with our business practices and ethical supply policies and our site induction processes extend to sub-contractors’ workers operating on our sites. We also focus on embedding awareness of ethical risks, such as Modern Slavery, and engaging in discussion with our key suppliers on the steps they are taking in our supplier engagement meetings.
6. For our UK located businesses, the substantial majority of their transactions are with other UK based organisations which are themselves subject to the Modern Slavery Act.
7. In the operations of our main area of Modern Slavery risk is in the supply chain. We are conducting ongoing audits on the work sites and worker welfare standards of all labour suppliers and of the key sub-contractors. Our sub-contract agreements and purchase orders are being amended to include reference to ILO standards. Compliance will be reinforced through random audits undertaken on a risk-based basis.
8. The approach to the recruitment of the directly employed workforce by our companies is based on explaining terms and conditions of employment in an understandable way, sourcing candidates only through approved labour supply agencies, following up with face to face interviews of potential candidates in their country of work and ensuring that employees are paid on time, utilising Government operated payment schemes where available. Employee’s passports are not held as a matter of course, but can be stored on their behalf in a secure environment upon request.
9. We are undertaking activities across our own business and with our supply chain to raise awareness of Modern Slavery. Appropriate training will be provided to those who are responsible for bringing agency workers and sub-contractors on to site, and for relevant procurement staff.
10. As part of our ongoing business improvement we will continue to review our policies, procedures, capabilities and capacity in respect to Modern Slavery over the coming months. This statement may be revised to reflect the findings of the review and our response to it.
11. We will be further developing our performance indicators to assist in monitoring the effectiveness of our policy, including tracking of any incidence of Modern Slavery highlighted through the whistle-blowing process, and conducting regular checks for multiple payments to the same bank account in the UK.
12. The Supply Chain Sustainability School special interest group, of which we are an active member, is looking to establish a common approach to tackling Modern Slavery across the Enigma businesses. This will help drive consistency in what is required of the supply chain in these industries and provide material that will help them to prevent Modern Slavery in their own operations and supply chains. We will actively promote this material within our key supply chain when it becomes available.

This Modern Slavery statement has been approved by the board of directors.

Scott Hardie – Managing Director

Signed January 2024