Modern Slavery Policy

A) ORGANISATION
This statement applies to Fieldway Group Ltd (referred to in this statement as “Fieldway”). The information included in this statement relates to the financial year 2025/2026.

B) ORGANISATIONAL STRUCTURE
Fieldway works predominately across the United Kingdom, delivering specialist refurbishment, compliance, fire safety, decarbonisation and planned maintenance services.The company operates on a regional basis and overall control is served by the main office which is in Liverpool. Working across the social housing, public sector, healthcare, education and defence sectors, Fieldway provides a wide range of property improvement and building safety solutions.

Fieldway undertakes projects on a client-led, contract-specific basis. Work is delivered through a combination of directly employed staff, approved subcontractors and carefully selected suppliers. As a result, project locations vary across the UK depending on client requirements and contractual commitments.

Fieldway undertakes projects on a client-led, contract-specific basis. Work is delivered through a combination of directly employed staff, approved subcontractors and carefully selected suppliers. As a result, project locations vary across the UK depending on client requirements and contractual commitments.

The labour and services supplied to Fieldway in support of its operations are primarily sourced within the United Kingdom and are subject to applicable UK employment legislation and standards.

C) DEFINITIONS
Fieldway considers that modern slavery encompasses:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or to have restriction placed on freedom of movement.

D) COMMITMENT
Fieldway acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions of the Modern Slavery Act 2015. Fieldway recognises that this requires ongoing review of both its internal employment practices and its supply chains.

Fieldway does not knowingly enter into business with any organisation, within the United Kingdom or overseas, that supports or is found to be involved in slavery, servitude, forced labour or human trafficking.

No labour provided to Fieldway in the delivery of its services is obtained through slavery or human trafficking. Fieldway is committed to fair employment practices and adheres to all relevant employment legislation, maintaining high standards of ethical conduct throughout the business.

E) SUPPLY CHAINS
In order to fulfil its activities, Fieldway’s principal supply chains include the provision of construction materials, specialist building products, subcontractor services and labour.

These services are sourced predominantly from suppliers and subcontractors operating within the United Kingdom and therefore subject to UK legislation and employment standards. Fieldway expects all suppliers, subcontractors and business partners to operate in accordance with applicable laws and ethical business practices.

Suppliers and subcontractors are assessed through approval and performance review processes, with ongoing monitoring undertaken to ensure compliance with Fieldway’s standards and values.

F) POTENTIAL EXPOSURE
Fieldway recognises that the construction, refurbishment and property maintenance sectors may be exposed to risks associated with labour exploitation, particularly within complex supply chains.

Potential exposure may arise through the procurement of imported materials, labour-intensive services or subcontractor arrangements. While Fieldway considers the risk within its direct operations to be relatively low, it remains vigilant and continues to review and monitor its supply chain to identify and mitigate any potential risks.

Fieldway is committed to ensuring that modern slavery does not occur within its business or within any organisation that supplies goods or services on its behalf.

G) STEPS
Fieldway carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

Fieldway has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, Fieldway has taken the following steps to ensure that modern slavery is not taking place:

• Board level commitment to the implementation of the Modern Slavery and Human Trafficking policy
• The supplier approval process will incorporate a review of the controls undertaken by them prior to them being included on the preferred suppliers list
• Monitoring as part of the Contractor Assessment process and when working overseas as part of the Contractual arrangements agreed
• Zero tolerance, Fieldway will not support or deal with any business knowingly involved in slavery or human trafficking
• Developing and implementing codes of conduct in line with Fieldway values and societal moral values
• Providing training, posters, awareness material and guidance on recognising modern slavery
• Working with overseas clients who share similar values to evaluate local labour and material suppliers
• Carrying out supply chain audits
• Implement and embed an open door speak up philosophy throughout the business

H) KEY PERFORMANCE INDICATORS
Fieldway has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in Fieldway or its supply chains.

• Zero occurrences of modern slavery through supplier audits
• All staff trained in modern slavery
• Internal audit findings

I) POLICIES
Fieldway has the following policies which further define its stance on modern slavery

• Ethical Purchasing Policy Statement
• Subcontractor & Supplier Code of Conduct
• Recruitment and Selection Policy
• Modern Slavery and Anti Trafficking Policy Statement

J) TRAINING
Fieldway provides the following training to staff to effectively implement its stance on modern slavery.

Initial Training is via company induction, review and the staff handbook.

Ongoing training is undertaken in the form of toolbox talks, awareness posters and supply chain school videos.
https://www.supplychainschool.co.uk/default/modern-slavery.aspx
https://www.supplychainschool.co.uk/uk/fir/construction/default.aspx

We also download a variety of posters in various languages from the Government website.
https://www.gov.uk/government/publications/modern-slavery-closer-than-you-think

K) SLAVERY COMPLIANCE OFFICER
All employees, sub-contractors and suppliers for Fieldway act as Slavery Compliance Officers, all concerns regarding modern slavery should be addressed via email to the Fieldway compliance team at alicia.mcgivern@fieldway.co.uk, who will then undertake relevant action with regard to Fieldway obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2026 and will be reviewed for each financial year.

Downloadable PDF: Fieldway – Modern Slavery Policy
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