Modern Slavery Transparency Statement

Statement

The purpose of this statement is to confirm that Hemiko Limited and other relevant group companies (“Hemiko”) have taken appropriate steps during the year ending 31 March 2025 and will continue to do so in future years to ensure our continued compliance with the Modern Slavery Act 2015 (the “Act”). As a business we are committed to improving our practices to combat slavery and human trafficking in our business and supply chain. We continue our commitment to providing employment opportunities which are non-discriminatory, support real living wage legislation, and offer regular hours and working conditions that are safe and hygienic. We are also committed to implementing and enforcing effective systems and controls to ensure that there is no modern slavery or human trafficking taking place anywhere in our own business or in any of our supply chains.

About us

Hemiko is a fast-growing, innovative business looking to invest in and deliver over £1bn of heat network projects in the coming years. The business’s vision is to be a leading provider of decarbonised heat in the UK. We do this through funding, designing, building, operating and maintaining low carbon district energy networks and building energy systems. Where possible we connect waste heat sources into our networks so this heat can be used to meet hot water and central heating demand instead of being wasted. We work with local authorities, developers, house builders and property owners to decarbonise communities, towns and cities.

We currently operate solely across the United Kingdom and pride ourselves on our reputation for acting fairly and ethically wherever we do business. Our reputation is built on our company values, those of our employees, and our collective commitment to acting with integrity throughout the organisation, This statement covers all aspects of Hemiko Limited’s business falling within the scope of section 54(2) of the Modern Slavery Act 2015.

Further business information can be found at: https://www.hemiko.com

Hemiko is heavily reliant on its people and supply chains in the delivery of services. We are also aware of our diverse customer base with a wide range of backgrounds and needs. Each business within the group is responsible for ensuring that they can demonstrate compliance with the Act by working to our policies and procedures.

Our business in relation to slavery and human trafficking Hemiko prides itself on having a reputation for being a moral and principled employer. We believe this provides a platform to deliver a quality and more consistent service across our contracts and sends a message that we care about the wellbeing of the people working for us.

We are an accredited Living Wage Foundation employer ensuring we meet these requirements and regularly review our terms of employment to ensure that they comply with all relevant legislation.

Policies in relation to Slavery and Human trafficking

Hemiko has a set of policies and procedures which include human rights issues and are aimed at minimising the risk of slavery or human trafficking. Our policies are reviewed on an annual basis, or more regularly as required by any legislative change.

In addition to our Modern Slavery Policy, some of the policies and procedures of particular note are our Supplier’s Code of Conduct, Diversity, Equity and Inclusion, Grievance, Harassment and Discrimination, and Whistleblowing, each of which is easily accessible and available to all staff electronically via our document sharing system. Additionally, all new staff are provided access to, and explained how to access these key documents as part of their HR induction process. Any changes to policy are communicated to all staff via email, and this year will be reinforced with copies sent via our document sharing system.

Our employee, customers and suppliers are encouraged to report any concerns or suspicions they have that any unlawful conduct, including slavery or human trafficking, is taking place at work. For our staff, we have introduced a dedicated and confidential SpeakUp@hemiko.com email inbox to facilitate this.

We also promote the Modern Slavery Helpline 0800 0121 700 (https://www.modernslaveryhelpline.org), where individuals can report any suspicious activity or seek help and advice in confidence.

In an effort to combat the hidden nature of modern slavery and boost awareness of the signs, we now display posters and infographics created by the UK Home Office (part of the ‘Modern slavery is closer than you think’ briefing documents) in company office notice boards. Our regular internal communications provide links to a UK Home Office short film and other relevant information to further educate the business.

Our processes are designed to:

• establish and assess areas of potential risk in our business and supply chains,

• monitor potential risk areas in our business and supply chains,

• reduce the risk of slavery and human trafficking occurring in our business and supply chains, and

• provide adequate protection for whistle-blowers.

Our supply chain in relation to slavery and human trafficking

We have zero tolerance to slavery and human trafficking. We expect our suppliers, contractors and subcontractors to work to the same high standards that we impose on ourselves. We actively promote safe and fair working conditions, including the responsible management of environmental and social issues within our supply chain.

Through our procurement processes we monitor our supply chain to ensure only reputable suppliers and contractors who share those same high standards and comply with our values remain on our preferred supplier list.

The majority of our suppliers are UK-based and include, micro, small and medium-sized businesses, national suppliers, and contractors. We also source some products from Western Europe. Our goal is to continue to drive as much of this spend as possible through UK businesses and local supply chains, which continue to support both our modern slavery and social value commitments.

Due Diligence processes

All staff employed by Hemiko have identity and Right to Work checks and, where applicable, DBS checks prior to employment commencing. These checks are always carried out in line with the relevant legislation and in accordance with latest UK Government guidance. For certain roles, where additional background checks are required, a more in-depth vetting process can be implemented.

Our HR information system provides us excellent transparency in this area, additionally DBS workflows and reporting incorporate 2-yearly checks, significantly reducing any compliance risk.

Each year we conduct an engagement survey for our staff which asks them to anonymously comment on their experience in the workplace and beyond. Throughout the survey there are frequent free text fields allowing the opportunity to provide honest feedback or raise concerns. All staff are encouraged to complete the detailed questionnaire and are informed of the purpose. The data collected is used to identify areas of improvement and flag any areas of concerns or issues. We are also in the process of launching targeted surveys for onboarding and exiting staff.

As part of our supplier onboarding process, all suppliers are required to complete various due diligence checks and they return a signed copy of our Supplier Code of Conduct. We assess our supply chain for potential areas of risk of non-compliance with the Act.

As part of the pre-qualifying and onboarding process we request information from our suppliers which includes but is not limited to:

• Modern Slavery statement and/or policy

• Pay National Living wage to its employees

• Hold all the relevant industry standard accreditations (e.g. Safe Contractor)

• Meets the minimum health and safety standards of Hemiko

• Check for other internal policies held such as Bribery Act, Health & Safety, Environmental, EDI etc.

This year we have improved, and will continue to improve, our engagement with our suppliers to ensure that we have a more detailed understanding of our supply chain. We are doing this by completing a full supplier audit, segmentation of the supply base, embedding new and more robust due diligence checks with internal visibility and performance reporting, we are also relaunching and automating our supplier pre-qualification onboarding process. Additionally, we are introducing further financial controls within the business to enable greater control over our supply chain.

Tendering

Hemiko has a robust tendering procedure which includes an obligation for suppliers to demonstrate they support and operate in accordance with the Act, we prioritise those with a strong commitment to ensuring there is no modern day slavery in their own supply chain, have good ethical sourcing standards and who can best demonstrate they have appropriate policies and practices in place.

Within our tender documentation we include a clause stating we expect any supplier of Hemiko to ensure its supply chain adheres to the same terms and commitments for modern slavery as those between Hemiko and the supplier.

Hemiko reserves the right to terminate any supplier or contractual relationship where there is a breach of the Act, and we continue to identify and prioritise suppliers that have their own modern slavery policy

Our Supplier Code of Conduct (the “Code”) includes key modern slavery provisions (i.e. equal pay, working hours compliant with legislation etc.). The Code is integrated into our supplier on-boarding process, meaning all new suppliers are required to review and confirm they will adhere to these principles.

Risk Assessment and Management

The Hemiko Board is ultimately responsible for the review and oversight of any risk relating to Modern Slavery. As such, levels of staff training and incidents that are reported via our speakup@hemiko.com email address are raised with and addressed at board meetings regularly.

As a business we regularly evaluate the level and nature of any risks of modern slavery or exploitation, in both our own practices and those of our supply chain. We have a whistleblowing policy in place and, as part of our efforts to identify and mitigate risks within our supply chain, we are introducing systems to identify, assess and monitor potential risk areas.

Furthermore, we conduct periodic audits of our key suppliers where safe and fair working conditions, including the responsible management of environmental and social issues within our supply chain, are reviewed.

Staff training about slavery and human trafficking

Our policies are communicated to staff from the point of induction and regular updates are provided as required through training programmes as the business sees fit. We invest in educating our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programmes, employees are encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy. Employees are taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains

Our policies and procedures are reviewed on an annual or bi-annual basis, or more frequently where legislation or regulation updates dictate, to ensure that they remain fit for purpose. Of particular relevance are our policies on safeguarding and vulnerability issues, mindful of our diverse customer base and workforce.

Over the next twelve months, we will continue to roll out training from our human resources to all staff, focusing on our higher risk teams, procurement, commercial and operational teams to increase their awareness of the Act and our associated due diligence processes. As part of induction training for new starters and refresher training for existing staff, staff are reminded of our core policies, including the Whistleblowing policy and who to contact with any concerns. The HR team conduct or oversee the Right to Work checks in accordance with the applicable legislation.

Our Continued Commitment

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Hemiko’s modern slavery and human trafficking statement for the financial year ending 31 March 2026 as approved by the Board of Directors on 4th September 2025.