Modern Slavery Act

Effective from January 4th 2023

Introduction
This statement is made pursuant to section 54(1) of the U.K. Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for the Kellaway Group. This Act requires us to publish a statement each year describing the steps taken to ensure modern forms of slavery and human trafficking are not taking place in the company’s business operations and supply chains. This statement covers the activities of all our Group companies, which procure goods and services from and form part of Group supply chain.

Kellaway Group is committed to operating responsibly and establishing high ethical standards across all businesses. We will not tolerate any breaches of human rights in our business.

Our Business
Kellaway Group distributes building materials to small through to large contractors in the wider construction sector as well as local tradespeople and the public. Kellaway Group has five main trading entities trading from over 28 locations. Many of our purchases are routed through NBG, which is a major buying group for independent builder’s merchants with 84 members, 300 depots across the UK and a turnover of £750m.

Our Principles and Policies
The way that we conduct business reflects our commitment to the highest ethical standards. Our code of business conduct supports a wide range of topics related to the protection of human rights,
including harassment and discrimination, workplace violence, protecting employee privacy, antimony laundering and anti-bribery.

Kellaway has other formal policies intended to promote ethical and legally compliant business conduct. Policies contributing to our commitment to preventing violations of human rights such as
modern forms of slavery in our business include:
• Dignity at Work Policy
• Health and Safety Policy
• Whistle Blowing Policy
• Data Protection Policy

Each year Kellaway staff are required to complete training on all the above policies and other policies relevant to their jobs. All staff, as well as anyone acting on behalf of the Group or any Group company, must comply with the above. Any breaches will face disciplinary action, which could result in dismissal for gross misconduct.

Kellaway continues to monitor relevant legal developments relating to human rights and modern slavery to maintain its commitment to operating responsibly and maintaining our high ethical
standards across the Group.

Our Supply Chains
Kellaway Group is committed to ensuring modern forms of slavery and human trafficking are not present in our supply chains and in any of our businesses. We expect businesses, companies, and other entities that provide, or seek to provide, any kind of good or service to the Group, including our suppliers, vendors and contractors (“suppliers”) to respect human rights and promote similar
principles in their own supply chains.

Where non-compliance is identified, Kellaway will engage with the relevant supplier and promptly take appropriate action, which may include not appointing or re-appointing the supplier.
We are aware that some of the products we purchase for resale originate from areas of the world where human rights are not respected. We ensure that all suppliers that source from such regions
have the highest standards, policies and are internally audited ensuring slavery is not used and local people are treated ethically. NBG also act on our and all partners behalf, to ensure the highest
standards are set and maintained.

Reporting
Kellaway Group is committed to transparency in its approach to respecting human rights. We will continue to review any areas of concern highlighted through our Supplier Commitments Programme and work alongside suppliers, customers and interested organisations to eliminate risk from our businesses and supply chain.