Introduction

Modern slavery is a serious criminal offence and a breach of fundamental human rights. It can take a number of forms, including forced labour, servitude, human trafficking, and exploitation, all of which involve the control of individuals for personal or commercial gain.

Giants Group Contracts is committed to maintaining the highest ethical standards in all areas of our business. We operate a zero-tolerance approach to modern slavery and are dedicated to preventing it from occurring within our operations and throughout our supply chain.

Our Commitment

We are committed to acting with honesty, integrity, and transparency in all business relationships. This includes taking appropriate steps to ensure that modern slavery and human trafficking do not take place within our organisation or among those we work with.

We expect all contractors, suppliers, and business partners to uphold the same standards. Our procurement and contracting processes include clear expectations that forced, bonded, or trafficked labour must not be used at any stage of service delivery.

Scope of This Policy

This statement applies to everyone working for or on behalf of Giants Group Contracts, including:

• Employees at all levels
• Directors and senior management
• Agency staff and temporary workers
• Subcontractors and suppliers
• Consultants, agents, and third-party representatives

All individuals are expected to understand and comply with this policy.

Responsibility and Oversight

Overall responsibility for implementing and maintaining this policy sits with senior management.

James Harris has responsibility for overseeing compliance, ensuring appropriate controls are in place, and reviewing the effectiveness of measures taken to prevent modern slavery.

Managers at all levels are responsible for ensuring that their teams are aware of this policy and receive any necessary guidance or training.

Identifying and Reporting Concerns

Preventing modern slavery is a shared responsibility. All individuals working with or for us must remain vigilant and take reasonable steps to identify and prevent potential risks.

You must not engage in, support, or ignore any activity that could indicate modern slavery or exploitation.

If you have any concerns or suspicions, you are encouraged to report them as soon as possible. This can be done by:

• Speaking directly to your line manager
• Escalating the issue to senior management

If you are uncertain whether a situation constitutes modern slavery, you should still raise the concern so it can be properly assessed.

Protection for Whistleblowers

We are committed to creating an open and supportive environment where concerns can be raised without fear.

Anyone who reports a concern in good faith will be supported, regardless of whether the concern is ultimately substantiated. We will not tolerate retaliation, discrimination, or any form of negative treatment as a result of raising a genuine concern.

If you believe you have been treated unfairly for raising an issue, you should report this immediately.

Supply Chain Standards

We recognise that risks of modern slavery can arise within supply chains, particularly in construction and utilities sectors.

To mitigate these risks, we:

• Set clear expectations for ethical labour practices
• Require suppliers to comply with relevant laws and standards
• Reserve the right to review and assess supplier practices
• Expect suppliers to apply the same standards within their own supply chains

Failure to meet these standards may result in termination of business relationships.

Breaches of This Policy

Any breach of this policy will be taken seriously.

Giants Group Contracts reserves the right to terminate relationships with individuals, contractors, or organisations found to be in violation of this policy.

Continuous Improvement

We are committed to reviewing and improving our approach to tackling modern slavery. This includes monitoring risks, updating procedures where necessary, and ensuring ongoing awareness across the business.

Approval

This statement has been approved by senior management and will be reviewed annually.

James Harris Managing Director
Giants Group Contracts
Date:  January 2026