1. Policy Statement

Ninety Four Group is committed to preventing slavery and human trafficking in all aspects of our business and supply chains. We uphold the highest standards of integrity and ethical conduct and expect the same from our partners, suppliers, and contractors.

We fully support the principles of the Modern Slavery Act 2015 and are dedicated to ensuring that modern slavery, in any form, has no place in our operations.

2. Scope

This policy applies to all employees, contractors, consultants, suppliers, and any other individuals or organisations working with or on behalf of Ninety Four Group.

3. Our Business

Ninety Four Group is a project consultancy firm operating in the real estate sector, delivering tailored solutions to clients across the UK. While our direct operations are low risk in terms of modern slavery, we recognise that risks may exist in our extended supply chains.

4. Our Commitments

We are committed to:

• Conducting due diligence on our supply chains to identify and mitigate risks of modern slavery.
• Including anti-slavery clauses in contracts with suppliers and partners.
• Training relevant staff to recognise and respond to signs of modern slavery.
• Encouraging the reporting of concerns and protecting whistleblowers.
• Reviewing and updating this policy annually to ensure its effectiveness.

5. Due Diligence and Risk Management

We assess the risk of modern slavery in our supply chains based on:

• Geographic location
• Industry sector
• Nature of goods and services provided
• Where higher risks are identified, we take additional steps such as supplier audits or requiring evidence of compliance with anti-slavery standards.

6. Training and Awareness

We provide training to staff involved in procurement and project management to ensure they understand the risks of modern slavery and how to respond appropriately.

7. Reporting Concerns

Employees and third parties are encouraged to report any concerns related to slavery or human trafficking. Reports can be made confidentially and without fear of retaliation.

8. Responsibility for the Policy

The Directors of Ninety Four Group are responsible for implementing and reviewing this policy.

All employees are expected to comply with it and report any breaches.