Modern Slavery Act

Updated 12 September 2025

This Modern Slavery Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. It sets out the steps that Kellaway Group has taken, and continues to take, to understand, prevent and address the risks of modern slavery and human trafficking in its business and supply chains. It has been approved by the Board / senior management of Kellaway and will be reviewed annually.

1. Our Business

Kellaway Group sells building materials to contractors, tradespeople, and the public through multiple branches across the UK. Our operations include five main trading entities operating from over 28 locations. We also make many of our purchases via the National Builders’ Buying Group (NBG), which serves a wide network of merchants.

2. Our Commitment & Ethical Principles

• We are committed to operating ethically and with respect for human rights. We do not tolerate slavery, human trafficking, forced labour, or child labour in any part of our business or supply chains.
• Our employment practices include a Code of Practice which prohibits all forms of forced or compulsory labour, prohibits child labour, protects freedom of association, and supports the right to collective bargaining.
• Kellaway has other formal policies in place to support these commitments, including:
  • Dignity at Work Policy
  • Health & Safety Policy
  • Whistleblowing Policy
  • Data Protection Policy
  • Anti‑Bribery & Corruption Policy
• Everyone in our Group Companies (employees, management, contractors) is required to adhere to these policies. Breaches may lead to disciplinary action, up to and including termination.

3. Risk Assessment & Due Diligence

To ensure we identify, assess and mitigate risks of modern slavery, we commit to:

• Conducting regular risk assessments of our supply chains, focusing on high‑risk commodities, regions, and supplier practices.
• Identifying suppliers required by law to publish Modern Slavery Statements, and checking whether they are compliant.
• Evaluating prospective suppliers’ modern slavery / human rights policies or statements as part of our supplier onboarding process.

4. Supplier Monitoring, Compliance & Remediation

• If instances of non‑compliance are identified, Kellaway Group will engage with the supplier to understand the issues and require corrective action. Depending on severity, this may include suspending or terminating the relationship.
• We will continually raise awareness across the business about modern slavery, our obligations under law, and our own policies and values.

5. Transparency, Reporting & Continuous Improvement

• Kellaway Group will publish this statement annually, ensuring full Board / senior management approval.
• We will review and update this Statement and our policies regularly, taking into account changes in legislation, industry best practice, and our own monitoring findings.
• We will encourage and collaborate with other organisations, suppliers, trade groups, and stakeholders in the building supplies sector to share knowledge, improve standards, and develop more effective practices.

6. Structure & Accountability

• The Board of Directors of Kellaway Group takes overall responsibility for this Statement and its implementation.
• Day‑to‑day responsibility lies with senior management in Procurement / Supply Chain.

7. Definitions & High‑Risk Areas (Examples)

To clarify what we mean by modern slavery and where risks are higher, we draw on recognised definitions and focus on:

• Modern Slavery: Forced labour, human trafficking, debt bondage, servitude, forced or compulsory labour, etc.
• Child Labour: Employment of children below the minimum legal age, work that interferes with education, or hazardous work for minors.

8. Statement of Approval

This Modern Slavery Statement has been approved by the Board of Directors of Kellaway Group and applies to the financial / reporting year ending August 2025. It will be reviewed and updated each year.