Anti-Slavery and Human Trafficking Statement for the financial year ending 2026/2027 (Year ending April 2027).

1. Introduction

Coinford Holdings Ltd (06885002), Coinford Ltd (05256144), Coinford Central Ltd (07072849), Coinford Construction Ltd (02539207), Coinford Plant Ltd (06736352), Formco Construction Ltd (06798011) and Manco South Ltd (9434310) and Onyx Highways Ltd (16914666) (together, "Coinford") maintain a zero-tolerance approach to modern slavery and human trafficking.

We are committed to conducting business ethically and transparently. This includes implementing and maintaining effective systems and controls to prevent any form of modern slavery or human trafficking within our own operations or supply chains.

This statement is made in compliance with Section 54(1) of the Modern Slavery Act 2015 and takes into account relevant provisions of the Economic Crime and Corporate Transparency Act 2023.

2. Our Business and Organisational Structure

Coinford is a specialist contractor in groundworks and reinforced concrete frame construction. We deliver contracts ranging in value from £750,000 to £50 million across London and the Southeast of England.

We operate through a group structure that enables close oversight and alignment of standards across all group entities.

3. Our Supply Chains

Our supply chains support our construction operations and include:

• Building materials (e.g., concrete, steel, aggregates)

• Plant and equipment (both owned and hired)

• Direct and indirect labour (employees, agencies, and subcontractors)

• Subcontractors providing materials, labour, or plant

4. Our Policies on Modern Slavery and Human Trafficking

Coinford is committed to ensuring modern slavery and human trafficking have no place in our operations. Our relevant internal policies include:

• Economic Crime Policy

• Right to Work and Recruitment Policy

• Whistleblowing Policy

These policies set out clear expectations for employees, suppliers, and subcontractors and are reviewed regularly to ensure compliance with current legislation and best practice.

5. Due Diligence and Risk Management

We recognise that some areas of our supply chain may present higher risk. As such, we have implemented the following due diligence measures:

• All suppliers and subcontractors are subject to a formal approval process, which includes reviewing their compliance with anti-slavery legislation.

• Contractual agreements include clauses requiring suppliers to confirm compliance with the Modern Slavery Act 2015.

• We prioritise working with UK-based suppliers and minimise engagement with higher-risk jurisdictions.

• A supply chain risk assessment is undertaken annually to identify areas requiring enhanced scrutiny.

• Suppliers are expected to undertake their own due diligence throughout their respective supply chains.

• Where concerns are identified, Coinford reserves the right to suspend or terminate relationships with suppliers or subcontractors who fail to meet our ethical and legal standards.

6. Monitoring, Reporting and Continuous Improvement

Coinford is committed to transparency and accountability. Our monitoring and reporting processes include:

• Internal whistleblowing procedures for reporting concerns, with protections in place for those who speak up.

• Checks to verify Right to Work documentation for all employees and CIS workers.

• Ongoing review of procurement contracts and supplier terms.

• Regular internal audits of our onboarding and HR processes to ensure compliance with legislation.

7. Training and Awareness

We continue to raise awareness among our teams by:

• Briefing procurement and commercial teams on current legislation and potential risk indicators.

• Providing regular updates to directors and senior leaders to maintain strong leadership accountability.

• Delivering awareness sessions and briefings to all staff, including operational managers and site supervisors, to support effective identification and reporting of modern slavery risks across our sites and supply chains.

8. Board Approval

This statement has been approved by the Boards of the relevant Coinford group companies and is signed by the CEO on their behalf. It will be reviewed and published annually in line with legislative requirements and best practice guidance.

Signed: Paul Timlin, Chief Executive Officer 

Date:     13/04/2026

Approved on behalf of Coinford Ltd

Review Date: Once a year or earlier if required.