Modern Slavery and Human Trafficking Statement 2025.

Introduction

This Modern Slavery Policy Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (“the act”) relating to Transparency in Supply Chains for the financial year ending 31 December 2024.

Avove recognises that it has a responsibility to take a robust approach to modern slavery and human trafficking and indeed takes a zero-tolerance approach to non-compliance with the Act in any part of its business or its supply chain.

It continues to be a priority for Avove to ensure that we trade ethically, source responsibly including working to prevent modern slavery and human trafficking throughout our organisation and in our supply chain. This statement highlights the key activities we have undertaken during this financial year to combat modern slavery in our organisation and supply chain.

Organisational structure

Avove operates predominantly in the utilities sector within the UK only.

Avove is a portfolio company of Rubicon Partners who are industrial investors based in London. The ultimate parent company of Avove is ERSA Topco Limited.

Avove had 792 direct employees on 31 December 2024. Registered Office is in Chorley, Lancashire.

Our business 

Avove’s business involves mainly design work, capital works, repairs and maintenance across the UK infrastructure and utilities sector.

Our governance for modern slavery

The Avove Executive Committee has overall responsibility in respect of the approach to Modern Slavery.

The Avove Executive Committee has established a Modern Slavery Working Group to review the approach to Modern Slavery, co-ordinate and monitor the activities of the business in this regard and to produce the annual statement for approval by the Board of Directors.

The group involves representatives from Procurement, People & Culture, Communications & Social Impact, and Legal.

Avove has reported no incidents of Modern Slavery during 2024.

Our policy on slavery and human trafficking

Avove is fully committed to reducing the risk of modern slavery or human trafficking occurring in its supply chain or in any part of its business and operates with zero tolerance for non-compliance.

This Policy applies to all Avove employees as well as suppliers and subcontractors who are obliged to ensure that their businesses and supply chains worldwide comply with the Act.

This Policy reflects that commitment to acting ethically and with integrity in all business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in the supply chain.

Suppliers and subcontractors must comply and act in accordance with this Policy.

We have the following policies in place relevant to Modern Slavery, which are reviewed annually and updated as necessary:

• This Modern Slavery and Human Trafficking Policy Statement
• The Avove Code of Ethics
• Responsible Sourcing & Procurement Policy
• Whistle Blowing Policy
• Recruitment & Selection Policy
• Security & Vetting Policy

Avove has an effective grievance and whistle blowing process and policy in place to manage and investigate any concerns within the business or the supply chain.

Our Supply Chains

Avove have been awarded the prestigious Chartered Institute of Procurement and Supply (CIPS) corporate kite mark for ethical procurement and supply.

Colleagues from our Procurement and Commercial Teams have successfully completed the CIPS training and passed the assessment, allowing us to operate under the CIPS kite mark.

Jon Doyle, Head of Procurement, said: ‘The CIPS kite mark is a statement of our commitment to ethical sourcing and supplier management. Being on this professional register elevates us alongside industry leaders and clients.”

Avove’s supply chain includes:

• Plant, vehicles, and equipment suppliers
• Subcontractors and other service providers
• Suppliers of contingent labour
• Manufacturers and suppliers of goods and materials

All procurement of services and supplies is undertaken by professional procurement specialists. The intention is to build and maintain long term sustainable relationships with suppliers encouraging collaborative working and exchange of innovative and good industry practices.

The supply chain includes approximately 1500 suppliers and subcontractors of varying sizes and expertise.

The onboarding process includes a questionnaire to procure:

• No forced labour or human trafficking is practised, and employment is freely chosen
• Working conditions are safe and hygienic
• Working hours are not excessive
• Compliance with National Minimum Wage
• No child will be exploited
• No harsh, cruel, or degrading practices are allowed
• No discrimination is practised

A failure to satisfy the above criteria is an absolute bar to pre-qualification as a supplier to Avove.

Certain areas require an enhanced level of diligence and Avove has taken a category specific approach, assessing the risk of Modern Slavery occurring within its business notwithstanding whether the deliverable is outsourced or delivered in-house. The emphasis can therefore be focussed on those categories considered most at risk.

The following procurement categories are considered to be of highest risk of Modern Slavery occurring:

• Provision of Personal Protective Equipment
• Recruitment
• Cleaning Supplies and Services
• Provision of Temporary Staff

Recruitment & Training

Avove undertakes pre-employment screening that includes identity checks and confirmation of entitlement to work in the UK for all employees prior to commencing employment. This is supported by Avove’s Right to Work Policy and the Employment Vetting Policy. 

As part of the onboarding process, on joining Avove each employee is given an overview of the essential policies and information in relation to those policies, procedures and other matters such as whistle blowing.

Avove has implemented a comprehensive training programme covering Modern Slavery and a range of other ethical matters. The Modern Slavery & Human Trafficking training itself has now been completed for 98% of Avove personnel.

Audit

In 2024 Avove sought to embed modern slavery audits within its routine visits and supply chain audits.

2025 Priorities

In 2025 Avove will progress the following actions:

• Renew training during Q2 with all employees via the Astute training platform
• Further imbed its supply chain and site-based audit process in respect of modern slavery with a proposed 6 account audits and 6 site based audits planned for the next year covering all activities
• Continue to collaborate with industry partners to ensure best practice is being applied

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes slavery and human trafficking statement for the financial year ending 31 December 2024. The statement has been approved by the Board of Directors of Avove Limited.

Mark Perkins

Executive Chair

10 April 2025