Modern Slavery and Human Trafficking Statement 2026

1. Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps taken by ACS Construction Group Ltd (“ACS”) to prevent modern slavery and human trafficking within its business operations and supply chains during the financial year ending 2026.

ACS is committed to operating responsibly, ethically and with integrity in all business dealings. We maintain a zero-tolerance approach to modern slavery and are dedicated to ensuring that our operations and supply chains are free from exploitation.

2. Our Organisation Structure, Business and Supply Chains

ACS Construction Group Ltd is a UK-based civil engineering contractor delivering infrastructure projects across the energy, industrial and commercial sectors. Our activities include:

  • Civil engineering works for energy infrastructure (including substations and associated works)
  • Enabling and infrastructure works for industrial and pharmaceutical clients
  • Earthworks, drainage, structural and reinforced concrete works

ACS operates with a direct delivery model, utilising a core team of directly employed personnel, supported by a supply chain of specialist subcontractors and suppliers.

Our supply chain typically includes:

  • Specialist subcontractors (e.g. piling, steel erection, mechanical and electrical packages)
  • Labour agencies (where required)
  • Material and plant suppliers
  • Professional services and design partners

Most of our operations are UK-based; however, elements of our supply chain may extend indirectly to international manufacturing and material sourcing.

3. Policies in Relation to Modern Slavery

ACS maintains a robust governance framework to ensure ethical working practices across the organisation.

This includes:

  • Modern Slavery & Human Trafficking Policy
  • Code of Conduct and ethical working standards
  • Recruitment and right-to-work procedures aligned with Home Office guidance
  • Whistleblowing procedures to enable confidential reporting

Our Modern Slavery Policy establishes a zero-tolerance approach and applies to all employees, subcontractors, and supply chain partners.

We require all suppliers and subcontractors to operate in accordance with the Modern Slavery Act 2015 and to maintain equivalent standards within their own operations and supply chains.

4. Due Diligence Processes

ACS undertakes proportionate and risk-based due diligence in relation to modern slavery across its business and supply chain.

Key controls include:

Supply Chain Due Diligence

  • Pre-qualification of subcontractors and suppliers prior to engagement
  • Assessment of financial standing, competency, and compliance credentials
  • Requirement for suppliers to confirm adherence to modern slavery legislation
  • Inclusion of modern slavery provisions within subcontract agreements

Recruitment and Employment Controls

  • Verification of right-to-work documentation for all employees
  • Direct employment model reducing reliance on third-party labour
  • Monitoring of labour-only subcontract arrangements where applicable

Ongoing Monitoring

  • Review of supplier performance and compliance throughout project delivery
  • Engagement with supply chain partners to reinforce expectations
  • Escalation procedures where concerns are identified

5. Risk Assessment and Management

ACS recognises that the construction and civil engineering sector presents inherent risks in relation to modern slavery, particularly where subcontracted labour and extended supply chains are involved.

Key risk areas include:

  • Use of temporary or agency labour
  • Lower-skilled or high-turnover workforce roles
  • Multi-tiered supply chains involving overseas manufacturing
  • Specialist subcontract trades with labour-intensive activities

To manage these risks, ACS:

  • Applies structured pre-qualification and selection processes
  • Maintains close site-level supervision and control of labour
  • Limits reliance on agency labour where practicable
  • Engages directly with subcontractors to ensure transparency
  • Promotes a culture of vigilance and reporting across all sites

6. Effectiveness and Performance Indicators

ACS is committed to continuously improving its approach to modern slavery prevention.

The effectiveness of our controls is monitored through the following key performance indicators:

  • 100% of subcontractors subject to pre-qualification prior to appointment
  • Right-to-work checks completed for all directly employed personnel
  • Ongoing monitoring of supply chain compliance throughout project delivery
  • Zero reported incidents of modern slavery within ACS operations (to date)
  • Regular review and annual update of policies and procedures

We recognise the importance of strengthening measurable indicators and will continue to develop our monitoring and reporting processes.

7. Training and Capacity Building

ACS provides training and awareness to ensure that employees and those working on our behalf understand the risks of modern slavery and their responsibilities.

This includes:

  • Modern slavery awareness incorporated into site inductions
  • Toolbox talks addressing recognition and reporting of risks
  • Ongoing communication and reinforcement through management teams
  • Leadership engagement to promote ethical working practices

Employees are encouraged to remain vigilant and to report concerns through established reporting channels without fear of reprisal.

8. Governance and Accountability

The Board of Directors retains overall responsibility for ensuring that ACS complies with its legal and ethical obligations.

Senior management are responsible for:

  • Implementing and enforcing this statement
  • Ensuring appropriate procedures are followed
  • Monitoring effectiveness and driving continual improvement

This statement is reviewed annually to ensure it remains aligned with legislation, industry best practice, and organisational requirements.

9. Group Statement and Applicability

This statement applies to ACS Construction Group Ltd and all associated operations and activities within the Group.

Where applicable, it covers all entities operating under the ACS Group structure and their respective supply chains.

The statement is published on the company website and made available to stakeholders, clients, and business partners.

10. Approval

This statement has been approved by the Board of Directors of ACS Construction Group Ltd.