Modern Slavery Act 2015 Policy And Statement

For Financial Year Ending 2025

INTRODUCTION

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and Community Windpower (Holdings) Limited and its group companies are committed to acting ethically and with integrity in all our business dealings and relationships. We will not tolerate slavery and human trafficking in our

business or our supply chain and are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

OUR BUSINESS AND SUPPLY CHAINS

Community Windpower (Holdings) Limited is a family run company with offices in Frodsham, Cheshire and employs around 40 people across the group companies. The organisation sources and develops land predominantly in Scotland for the purposes of generating renewable wind energy and property development. This statement applies to each of our group companies,

and all of their subsidiaries, regardless of their turnover.

Our supply chains are fairly limited and includes providers of professional services and contractors.

OUR APPROACH

Our suppliers of goods and services are based predominantly within the UK and EU, as we choose to use local suppliers wherever possible and we therefore expect those suppliers to have applicable anti-slavery and human trafficking policies in place. We expect all our suppliers to uphold the same standards and values that we do, and we will not forge relationships with any suppliers who are involved in modern day slavery and human trafficking.

We consider that we have robust employment practices for recruitment and management of our own staff. We ensure that our employees have an employment contract and are paid a salary which at least meets the minimum National Living Wage and are offered the required statutory annual holiday entitlement. Upon starting with the Company each new employee is taken

through an induction process and given a starter pack which includes all of the Company’s policies including the Disciplinary and Grievance Procedures which sets out the process that should be followed if a grievance is raised or disciplinary action is required. We maintain an extensive library of human resources practices and policies such that we are confident that the main risk of modern day slavery is more likely to arise in our supply chains than our own personnel.

We recognise the ongoing need to assess our business and obtain further information on the potential for risk of modern slavery. We are committed to continually developing our due diligence process and internal processes to identify and eradicate any risk of modern-day slavery and human trafficking within our business and our supply chains.

COMPLIANCE

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Everyone is required to avoid any activity that might lead to, or suggest, a breach of the Company’s Anti-Slavery and Human Trafficking policy.

The Anti-Slavery Policy encourages employees to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. If anyone believes or suspects a breach of this policy has occurred or that it may occur they must notify their line manager as soon as possible.

The policy also encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be

mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

In addition to our Anti-Slavery Policy, we also operate a number of internal policies that that reinforce our commitment to conducting our business in an ethical and transparent manner including:

  • Anti-Slavery and Human Trafficking Policy
  • Anti-bribery Policy
  • Whistle-blower Policy
  • Equal Opportunities Policy
  • Human Rights Policy
  • Risk Management Policy
  • Corporate Social Responsibility Policy.

Our Corporate Social Responsibility Policy is a continuing statement of our intent to meet the expectations of those affected by our work. The key strands of this are community, environment, our staff and business partners.

TRAINING

Training on the Anti-Slavery and Human Trafficking policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training

will be provided as necessary to ensure a high level of understanding of the risks.

MONITORING OUR PROCEDURES

As noted above, we believe the main risk of modern day slavery is most likely to arise in our supply chains. As part of our ongoing commitment to identifying, assessing and mitigating the risk of modern slavery and human trafficking within our operations and supply chains, we have implemented the following measures.

  • We provide employees with appropriate training and awareness to ensure they understand the nature of modern slavery, recognise potential indicators, and are aware of their responsibility to report any concerns or suspected incidents.
  • Our employee induction programme includes information on our obligations under the Modern Slavery Act and reinforces our commitment to ethical business practices. Our Anti-Slavery Policy and all other company policies are readily accessible to all employees.
  • Disciplinary action, up to and including summary dismissal for gross misconduct will be taken against any employee that is found to be in breach of our Anti-Slavery policy.
  • Our procurement processes require suppliers to confirm the compliance with the Modern Slavery Act and our expectations regarding ethical labour practices. Consideration of modern slavery risks forms part of our supplier engagement and due diligence activities.
  • Our standard contract terms and conditions, together with our supplier agreements, require suppliers and their subcontractors to comply with the requirements of the Modern Slavery Act. These agreements also provide us with the contractual right to terminate relationships where modern slavery or human trafficking has been identified of where there is an unacceptable risk of such practices occurring.

We continue to review our Anti-slavery policy and practices regularly and will provide information and/or training to all our employees on any changes we make. We will monitor our supply chain to ensure that high standards are maintained and to identify any potential issues with modern slavery and human trafficking.

GOVERNANCE

This statement constitutes our Modern Slavery Statement for financial year ending 2025 and has been approved by the Board of Community Wind Power (Holdings) Limited and each of its associated companies and their principal operating subsidiaries.

Rod Wood MBE
Managing Director
31st May 2026