Modern slavery – Nexus Infrastructure

Introduction

This statement is made in pursuant of section 54 of the Modern Slavery Act 2015 (the ‘Act’) and constitutes Nexus Infrastructure plc’s modern slavery statement for the financial year ending 30 September 2026.

The Act requires businesses to state the steps they have taken during the financial year to ensure modern slavery is not taking place in their operations or supply chains. Modern slavery incorporates offences of slavery, servitude and forced or compulsory labour and human trafficking.

Our Organisation

Nexus Infrastructure plc (including its subsidiaries), referred to in this statement as “Nexus” is a leading provider of essential infrastructure services operating in the East and South East of England. The business does not operate outside of the UK and directly employs in the region of 200 employees, all of whom are based in the UK.

To reinforce our commitment to ethical labour practices and employee wellbeing, Nexus Infrastructure plc recognises the intrinsic link between modern slavery prevention and health and safety compliance. In line with the Health and Safety at Work etc. Act 1974, we are committed to ensuring that all individuals working within our operations and supply chain are employed under safe, lawful, and humane conditions. This includes safeguarding against forced or exploitative labour, ensuring fair treatment, and maintaining environments free from physical or psychological harm. Our modern slavery controls are therefore embedded within our broader HSQE framework, supporting a culture of safety, dignity, and legal compliance across all levels of the organisation.

Nexus recognises our responsibility to take a robust approach to modern slavery and is committed to preventing modern slavery in all our activities and within our supply chain.

We consider our direct employee population to present a lower risk due to established recruitment, onboarding and payroll controls.

This statement outlines our approach to tackling modern slavery.

Our Supply Chain and Due Diligence

Our supply chain includes sub-contractors, employment agencies and suppliers of goods and materials. We have a zero-tolerance approach to modern slavery and require our supply chain to comply with this commitment.

Sub-contractors – We undertake due diligence on all sub-contractors. Each is required to complete a pre-qualification questionnaire before becoming an approved sub-contractor and modern slavery forms part of this questionnaire. Sub-contractors are required to confirm they conduct business within all applicable laws and regulations, including the Modern Slavery Act.
Suppliers of Goods and Materials – Each of our subsidiaries have a procurement department that operates a database of approved goods and materials suppliers. As part of our due diligence, we require new and existing suppliers to complete a Material Supplier Audit and confirm they conduct business within all applicable laws and regulations, including the Modern Slavery Act.
Employment Agencies – We undertake due diligence when considering taking on new suppliers of labour, and maintain a preferred supplier list of employment agencies who must comply with our Right to Work Policy (prevention of illegal working). Agencies are subject to regular audit.

Our Policies

Nexus has a number of polices which seek to minimise the risk of modern slavery. These include:

Right to Work Policy (prevention of illegal working) which sets out the requirement to conduct right to work checks for all employees to safeguard against modern slavery.
Anti-Bribery and Gifts Policy which confirms that we do not tolerate any form of bribery, whether direct or indirect. The Board and Senior Management are committed to preventing bribery, in accordance with the Bribery Act 2010.
Whistle-blowing Policy which provides employees with guidance as to how to raise any concerns, and reassurance that they can raise concerns in good faith without fear of reprisals.
Equality, Diversity and Inclusion Policy which sets out our commitment to ensuring that all employees are treated fairly and are provided with a working environment, which promotes dignity and respect to all.
Environmental, Social and Governance Policy which confirms that we actively look for opportunities to improve the environment and to contribute to the wellbeing of our employees and the communities in which we trade.
Bullying and Harassment Policy which confirms our commitment to promoting a working environment free from all forms of harassment and bullying.

Training and Advice

Modern slavery awareness training is provided to employees via e-learning. Training helps employees identify indicators of modern slavery and understand the process for reporting concerns. This statement, together with the polices outlined above, are made available to all employees via the Company intranet site and Document Management System. Each employee and, where applicable, all other individuals covered by our policies, have a responsibility to review our policies, as well as to ensure that they fully understand our obligations and the consequences associated with any breach of those obligations.

Within the last year we have;

Promoted a week-long campaign to raise awareness of modern slavery to all office and site employees explaining how to raise a concern which included Toolbox Talks and online elearning.
Reviewed our Code of Conduct for Labour Suppliers, confirming our commitment to the highest ethical standards of labour supply, which requires all our supply chain partners to adhere to the code.
Completed four audits on all employment labour suppliers to ensure compliance with right to work checks.
Conducted a thorough review of the due diligence process applied to employment agencies, to ensure an auditable and robust procurement process is implemented.
Continued to review the risk of modern slavery in our supply chain (both as regards to purchasing goods and the provision of services).
Continued to gain knowledge and understanding of the Government’s approach to minimise the risk of modern slavery practices, for use and implementation within Nexus and our supply chain.
Demonstrated our commitment to openness and accountability, by publishing our annual Modern Slavery Statement on the UK Government’s Modern Slavery Registry, where is available for public review.

Looking Ahead

For the 2027 financial year, we are committed to:

Continuing to strengthen our supplier due diligence processes, including assessing suppliers against modern slavery risks before engagement and periodically thereafter.
Keeping up to date with information about the latest trends used by modern slavery perpetrators, and best practice around tackling modern slavery.
Continuing to review the risk of modern slavery in our supply chain (both as regards to purchasing goods and the provision of services).
Continuing to raise awareness around modern slavery, explaining the principles of the Modern Slavery Act and how to raise a concern to new and existing employees.
Ensuring that the workplace shall be free of any form of harsh or inhumane treatment (such as harassment, mental or physical coercion or verbal abuse of employees).
Continuing to ensure that all employees will be treated fairly and equally and shall be paid at least the minimum wage required by applicable law. Wage payments shall be made at regular intervals and directly to all employees, in accordance with national law, and shall not be delayed, deferred or withheld.
Investigating all suspected cases or concerns of modern slavery, human trafficking or labour exploitation and taking appropriate action where required. which may include terminating relationships with non-compliant suppliers and implementing corrective actions to prevent recurrence or reporting concerns to the relevant authorities.

Approval

This statement was approved by the Board of Directors and constitutes the company’s Modern Slavery Statement for the financial year ending 30 September 2026. The Board will review and update it periodically and within the framework of The Modern Slavery Act 2015.

Dawn Hillman
Chief Financial Officer
1 October 2026