Legal

Modern Slavery Statement

Our Business and Structure

NES Fircroft is a global workforce solutions specialist providing contract, permanent (direct hire), managed and outsourced staffing services to clients across multiple industries and geographies. Our operations support customers in sectors including Oil & Gas, Power & Renewables, Infrastructure, Life Sciences, Mining, Automotive and Chemicals, delivering workforce solutions through a global network of subsidiaries and operational locations.

Our services are supported by centralised governance, compliance and risk functions and are delivered in accordance with our Integrated Management System, which is aligned to recognised international standards. This framework supports consistent operational practices, regulatory compliance and ethical conduct across our global business

NES Fircroft operates with a strong emphasis on compliance, integrity and responsibility. Our Core Business Values underpin how we operate and how decisions are made across the organisation. These values extend to the partners, agents and suppliers with whom we do business and inform our expectations around ethical conduct, human rights and decent working conditions.

Our Environmental, Social and Governance (ESG) programme aligns our strategies and operations with internationally recognised principles on human rights, labour, the environment and anti‑corruption. This programme supports oversight of sustainability‑related risks and reinforces accountability across our business structure.


REPORTING REQUIREMENTS//

This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and Section 16 of the Australian Modern Slavery Act 2018 (together, the Legislation). It sets out the steps taken by NES Fircroft Limited and its relevant subsidiaries to prevent modern slavery and human trafficking in our business operations and supply chains during the financial year ending 31 October 2025.

This statement applies to NES Fircroft Limited and the business entities listed in Appendix 1 and covers our global operations.


POLICIES AND GOVERNANCE FRAMEWORK//

NES Fircroft is committed to conducting business ethically, responsibly, and with respect for human rights. Our approach to preventing modern slavery is underpinned by a framework of policies, procedures, and governance controls, including:

  • Expected Business Conduct standards including Human Rights and Business Ethics policies.
  • A Code of Conduct for Business Partners & Suppliers.
  • Whistleblowing and incident reporting procedures.
  • Recruitment, onboarding, and placement controls.
  • Oversight through Risk, Compliance, Audit, and Legal functions.

These controls are embedded within our Integrated Management System, aligned to ISO9001 principles, and are subject to regular review and audit to ensure continued effectiveness.


RISK ASSESSMENT AND MANAGEMENT//

NES Fircroft recognises that modern slavery is a global issue and that risk may arise through geographic location, industry sector, or extended supply chains. While we continue to consider the overall exposure to modern slavery risk within our own operations and supply chain to be low, we acknowledge that higher risk may exist in certain jurisdictions or through indirect supplier relationships.

In 2025, modern slavery risk continued to be managed as part of NES Fircroft’s wider ESG and corporate risk framework, rather than as a standalone activity. Risk and impact assessments covering ethical, social and human rights factors were applied across both operations and supply chain activity, with escalation through the corporate risk register, internal audits or business incidents available where issues may arise.

This approach reinforces consistency, accountability and audit readiness, and ensures that any concerns relating to labour standards, supplier conduct or worker welfare could be tracked, reviewed and addressed through formal governance mechanisms.

We continued to review geographical and sector‑specific risk indicators during the reporting period, using internal data, external indices, and supplier assessments to inform ongoing monitoring and control measures.


DUE DILIGENCE IN OUR OPERATIONS AND SUPPLY CHAINS//

Our people and recruitment practices

NES Fircroft ensures that all employees and placed candidates are engaged freely and transparently. Our recruitment and placement processes include:

  • Clear employment and assignment contracts
  • Defined roles, locations, and remuneration
  • Compliance with local labour laws
  • Robust onboarding and induction processes

These measures are designed to prevent forced labour, unfair treatment, or exploitative practices and to ensure individuals are treated with dignity and respect.

Supplier due diligence

We apply a structured, risk‑based approach to supplier onboarding and monitoring. 
This includes:

During the reporting period, our integrated supplier management platform continued to support consistent and transparent due diligence processes across regions, enhancing visibility of human rights and modern slavery risks within our supply chain.

Remediation and response

While no confirmed instances of modern slavery were identified during the reporting period, NES Fircroft maintains procedures to respond appropriately should risks or concerns arise.

Where potential modern slavery indicators are identified, matters are escalated through established governance channels for investigation. Responses may include engagement with affected parties, corrective action plans with suppliers or service providers, enhanced monitoring, and, where necessary, suspension or termination of business relationships.

NES Fircroft’s approach to remediation is designed to be proportionate, risk based and aligned with respect for human rights, with a focus on preventing recurrence and supporting ethical and lawful working conditions.


TRAINING AND AWARENESS//

Training and awareness remain a key component of our approach to preventing modern slavery. All new employees are required to complete mandatory Business Ethics training via our Learning Management System, which includes content on human rights and modern slavery.

This training is applied across our global business and is subject to regular review, acknowledgement, and acceptance. Where appropriate, supplementary learning modules are deployed to support continued awareness and capability building.


REPORTING MECHANISMS AND GRIEVANCE PROCEDURES//

NES Fircroft provides multiple channels for raising concerns or reporting suspected wrongdoing, including:

  • Direct reporting to designated contacts
  • Business incident and deviation reporting procedures
  • A confidential and anonymous Whistleblowing Portal

These mechanisms are accessible to employees and relevant external parties and support a culture of openness, accountability, and early escalation of potential issues relating to human rights or ethical conduct.


EFFECTIVENESS OF ACTIONS TAKEN//

NES Fircroft assesses the effectiveness of its actions to prevent modern slavery through a combination of qualitative and quantitative measures embedded within its governance and compliance framework.

These include:

  • completion and ongoing monitoring of mandatory Business Ethics and human rights training for employees;
  • risk‑based supplier onboarding and screening outcomes, including the application of enhanced due diligence where elevated risk is identified;
  • review of issues raised through whistleblowing, grievance and incident reporting mechanisms, including analysis of themes and resolution outcomes;
  • Internal audit, compliance reviews and management oversight of recruitment, onboarding and supplier controls; and
  • periodic review of modern slavery risk indicators within the corporate risk and ESG frameworks.

These measures support ongoing evaluation of control effectiveness and inform targeted improvements to policies, processes and oversight arrangements.

During the reporting period, NES Fircroft did not identify any confirmed instances of modern slavery or human trafficking within our operations or supply chain. We recognise that the identification and prevention of modern slavery risks is an ongoing process and continue to monitor, review, and strengthen our controls to ensure their ongoing effectiveness.


CONTINUOUS IMPROVEMENT//

During the 2025 reporting period, NES Fircroft continued to embed and strengthen initiatives introduced in prior years, including:

  • Enhanced supplier due diligence processes
  • Integrated ESG risk management
  • Statutory reporting and accessible grievance/reporting mechanisms
  • Investment in resources to support monitoring and governance activities
  • Use of third‑party sustainability and assessment tools to support transparency and improvement in human rights and working conditions

These activities support our ongoing commitment to responsible business practices and continual improvement across our global operations.


CONSULTATION//

NES Fircroft continues to consult with the relevant operating companies and third-party consultants to assess any specific risks or impacts to our business and supply chain, that any risk is understood and incorporated to our risk management structures.

This Statement has been prepared following consultation with the corporate functions across our global business, including the entities owned or controlled by NES Fircroft Limited and relevant operating companies within the NES Fircroft Group that are covered by this Statement. Consultation was undertaken through engagement with regional and functional leads to gather and review information on operational practices, recruitment activities, supplier due diligence, risk assessment processes and reporting mechanisms relevant to modern slavery risks.


APPROVAL//

This Statement was approved by the Board of Directors of NES Fircroft Limited (the principal governing body) and is signed by a nominated delegate of the Board of Directors on behalf of the group businesses.

This Statement constitutes NES Fircroft’s Modern Slavery and Human Trafficking Statement for the financial year ending 31 October 2025 and progress made during the reporting period.

Approved by the NES Fircroft Board of Directors

Signed on behalf of the NES Fircroft Group

Ian Campbell 
Director of Risk, 2nd April 2026

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APPENDIX 01

This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and Section 16 of the Australian Modern Slavery Act 2018.  This statement applies to NES Fircroft Limited global operations and specifically and the business entities listed below as part of the businesses reporting requirements.

Our Modern Slavery Statement has been submitted to the relevant government registries. At the date of publication, the 2025 statement has not yet been formally approved by the Australian Attorney‑General’s Department (AGD).