The Dandara Group Modern Slavery Statement 2025.

Introduction to the Statement

This Modern Slavery Statement has been published by The Dandara Group. It covers the period of July 2024 – end of June 2025, in line with our Financial Year (FY25) and in accordance with the Modern Slavery Act 2015 (the Act).

This Statement sets out the steps taken by The Dandara Group to understand potential modern slavery risks related to our business and to prevent modern slavery and human trafficking in our business and supply chain.

The scope covers the activities of the Group within the jurisdiction of the UK. Although the Isle of Man and Jersey are not subject to the Act, our activities in these locations are included in the Statement to demonstrate a coordinated and best practice approach to reducing risk of modern slavery.

The Dandara Group

The Dandara Group, founded in 1987 includes a portfolio that spans the residential and commercial sectors, across the for sale and rental markets. In the years since the company began, we have developed and delivered thousands of homes and won numerous industry awards.

We operate in the Isle of Man, Jersey and across the UK. For the purposes of this statement, references to the Dandara Group mean those companies which meet the reporting threshold under the Act and are subsidiaries of Dandara UK Property Holdings Ltd and Dandara Living Holdings Ltd, including:

Dandara Northern Home Counties Limited Ltd; Dandara Southeast Ltd; Dandara Southern Ltd; Dandara Eastern Ltd; Dandara Wales & West Ltd; Dandara Aberdeen Ltd; Dandara East Scotland Ltd;
Dandara Living Development Ltd; Dandara Living Contracting Ltd; and Dandara Living Management Ltd*.

As mentioned above, the Group also refers to activities within the Isle of Man and Jersey.

*Please note, while not of impact for this Statement, Dandara Living Management Ltd has moved out of the Dandara Group as at 31/7/25 (FY26).

Our workforce is made up of permanent and temporary, office and site-based roles, employed both directly by the companies within The Dandara Group and via our supply chain partners.

During FY25, the Dandara Group directly employed approximately 840 people. We also use the services of Labour Supply Agencies to supply labour, trades and logistics and site services personnel as required across our sites. Furthermore, we have a diverse sub-contractor labour force, supporting hundreds of sub-contractor companies across our divisions, including groundworkers, housebuilding trades and security personnel.

Due to the different contract types that those working with and for us are on, we work with our supply chain partners to ensure that our due diligence extends beyond the first tier of the recruitment process. We apply appropriate employment practices and policies for each jurisdiction we work in and uphold high quality labour standards across the Group.

The following Statement sets out the steps we have taken in our FY25 and our plans for the next 12 months to advance our objectives around preventing modern slavery and human trafficking. It has been reviewed and approved by Steven Hannah, Director and directors of the Group companies.

Key Policies

The Dandara Group of companies have developed a suite of policies, procedures and commitments that support and respond to our compliance and governance requirements. These policies are reviewed and updated annually. This Modern Slavery Statement forms part of this suite of documents.

These policies are either available within the company governance and sustainability web pages or by request. For many of the companies within the Group, these policies are issued as part of contract documents.

Our Commitments outline the expected compliance requirements for workers’ welfare and conditions of employment and are reviewed annually. Our onboarding and procurement processes are aligned with these commitments and thus our supply chain partners are required to abide by this suite of documents as appropriate within each jurisdiction.

Due Diligence

Within the Dandara Group, due diligence by key departments is carried out to prevent modern slavery & human trafficking. Different departments across the business have varying responsibilities in relation to prevention of modern slavery risk. Individuals from Human Resources (HR), Health, Safety & Environment (HSE), Compliance, Commercial, Construction, Procurement, Legal and Environmental Social & Governance (ESG) are responsible for reviewing our current approach to preventing modern slavery within the Dandara Group.

Recruitment & Labour Supply

The Human Resources (HR) and Recruitment team play a critical role in combatting modern slavery by implementing and monitoring practices that reduce the risk of exploitation. Common modern slavery checks conducted by the HR & Recruitment team at Dandara include:

Upfront due diligence - at the very start of the recruitment process including “right to work checks” and verification of personal documents to prevent illegal recruitment practices.
Ensure that contracts clearly outline job roles, pay, working hours, and entitlements.
Highlight red flags, such as shared addresses, bank accounts, or irregular documentation.
Check housing conditions for compliance with health, safety, and dignity standards (Jersey / Isle of Man).
Worker Engagement – educating colleagues on rights and providing information about grievance mechanisms and whistleblowing policies.

In relation to the recruitment of site / short term workers, in general, the Dandara Group work with several labour supply agencies. We require our labour supply agencies to ensure that staff: are legally able to work within the jurisdictions where we operate; have written employment contracts; and have not had to pay for the opportunity to work. The labour supply agencies subject employees to checks to ensure they are genuine applicants including verification checks. The agencies also operate a supplier / subcontractor verification process which as well as the normal checks also include due diligence and a review of the controls undertaken by the supplier / subcontractor. In the Isle of Man and Jersey, these checks are carried out by our in-house team.

Our UK housebuilding division use a Recruitment Process Outsourcing (RPO) organisation to provide an independent compliance audit service to help ensure compliance across our recruitment supply chain via labour supply agencies within the UK (please note, we do not use these agencies on the Isle of Man). The RPO has been working with our labour supply agencies to assist in the reduction of modern slavery risk on an ongoing basis with reviews / audits carried out every 6 months.

Construction site personnel are asked to follow best practice and carry up to date Construction Skills Certification Scheme (CSCS) Card in the UK. Workers in Jersey are required to complete the required Jersey Safety Awareness Training (JSAT). As well as helping to demonstrate a level of competence amongst personnel to safely perform a specific job, these cards help confirm identity and right to work status. Jersey along with the Isle of Man uses a work permit system to regulate the employment of workers on the island. Typically, employers must apply for a permit for their employees on both islands respectively.

Supply Chain

The Dandara Group spends a significant proportion of revenue within our supply chain, through the procurement of goods and or services from our supply chain partners. Our supply chain is an integral part of our operations, and our success and reputation are linked to their performance and ethics. Our supply chain partners range from large global companies to small and medium businesses and social enterprises. The Dandara Group has developed strong, long-term relationships with many of these partners.

We understand that construction is a high-risk sector in relation to modern slavery due to complex supply chains and labour practices and we are committed to preventing slavery and human trafficking within our activities and those of our supply chain.

For our construction sites, our UK housebuilding group suppliers are required to complete a pre-qualifying questionnaire (PQQ) process. Part of the questionnaire focuses on reducing the risk of modern slavery occurring on our sites. During the year, the UK housebuilding division refreshed this group procurement PQQ process. Suppliers respond to an expanded series of queries on reducing risk of modern slavery with requests for information on compliance and whistleblowing. We also request information on materials / components that originate from high-risk countries. Volume suppliers (paper, sundries, consumables, cleaning products suppliers etc) are still being reviewed with the aim of being included in a future version of the PQQ process.

This Statement is published on our website(s) and will be issued in electronic format to suppliers as part of the onboarding process of new suppliers.

Contractors

Throughout the UK, our sub-contractors typically go through a PQQ Process where they confirm that they will reduce risk of modern slavery.

All contractors and site personnel working on our sites must go through a site induction process before working on our sites. This site induction includes the topic of modern slavery and attendees must sign that they have understood the process relating to modern slavery and human trafficking as well as how to report concerns.

The HSE Team in the UK Housebuilding division include a module on Modern Slavery as part of their Toolbox Talks series and they include Modern Slavery Information Bulletins as part of their updates to sites.

Training and Awareness

Modern Slavery now forms part of the Health and Safety training that is released to new employees, one week after their start date. Existing staff are mandated to complete a modern slavery e-learning module that will enable them to:

increase awareness;
inform participants how to spot the signs; and
give participant guidance on what to do in a suspected case of modern slavery.

Every 12 months employees will need to take a refresher online course on the topic.

Risk Management & Mitigation

We know that key activities, such as the procurement of materials and the use of subcontractors and labour agencies are amongst the key risks of modern slavery occurring within the construction industry. To mitigate this risk, we inform stakeholders that the Dandara Group has a zero-tolerance approach to modern slavery and will not work with supply chain partners or source materials from those who do not make efforts to reduce modern slavery risks associated with their own business and supply chain. In addition, we ensure that risks of modern slavery are covered within our PQQ and Onboarding processes. Appointment of a RPO has helped ensure a more comprehensive approach to due diligence and risk mitigation across different labour supply agencies.

The following table outlines the identified risks from the previous year’s Statement and how we managed and mitigated these risks over the last 12 months.

Table 1:Modern Slavery Risk Management and Mitigation

Category	Risk to Dandara	Management and Mitigation Progress during FY25	Continuous Improvement Targets and Next Steps for FY26
Material Suppliers	Using suppliers and sourcing materials from high-risk countries / locations with poor or lack of labour laws.	To mitigate risk, our UK Housebuilding division and Dandara Living carry out modern slavery compliance checks at pre-qualification and during on-boarding process. We understand that some materials and components such as solar photovoltaics (PV) are supplied from ‘high-risk countries’ represent a significant ethical risk in terms of modern slavery. Previously, an in-depth review of our solar PV supply chain was carried out. The outcome of this is that our Housebuilding division now works with a single PV provider. This PV provider demonstrated the most extensive auditing process (up to Tier 7) to help reduce the risks of modern slavery occurring within the supply chain tiers. This supplier is also a signatory of the Solar Stewardship Initiative (SSI) – a pan-European industry collaboration to increase transparency in the sector. As per actions identified in our previous Statement due diligence review was carried out into high-risk regions. This review enabled us to: Identify high-risk regions using tools like the Global Slavery Index; and Better understand which of the materials and supply chains we utilise are at high risk of labour exploitation using industry reports from the Ethical Trading Initiative. The outcome of this review is that the housebuilding division PQQ now includes specific mention of certain high-risk regions. Should our suppliers source materials from these regions, it triggers a request for further information. The procurement team then make an informed decision on whether to proceed with this supplier or not. In our FY24 Statement, the Group committed to developing a Supply Chain Charter. Following engagement with several of our major supply chain partners and a review of best practice charters, we concluded that the principles and requirements commonly set out in such charters are already embedded within our existing governance framework and ESG-related policies. To avoid duplication, the Group will therefore not produce a standalone Charter at this time. Instead, we will strengthen our Sustainable Procurement Policy and develop a standalone Modern Slavery Policy.	The business will review the PQQ process and identify the most appropriate whole supplier engagement and management process. Work towards establishment of a new supplier engagement and management process / standard across the Dandara Group. Engage with Certified Suppliers: prioritise partnerships with suppliers who adhere to recognised ethical standards and certifications. Review and Update sustainable Procurement Policy with particular emphasis on enhancing provisions relating to modern slavery risk (materials / regions). Stay Informed: Keep up to date of global developments and reports concerning labour practices in high-risk supply chains. Develop and publish a proportional a Modern Slavery Policy to set out our commitments to enacting practical steps to reduce to risk of modern slavery across our sites. Refresh our modern slavery information posters across our sites.
Labour Supply Agencies	Risk of labour supply agencies not completing continuous, extensive and robust checks.	To mitigate this risk, an RPO has been appointed and carries out regular audits of LSAs. This helps ensure that and further ensure compliance in relation to modern slavery. The scope of work for the RPO was extended to cover Jersey during FY25. In addition, the ESG team held calls with the main LSA on the island of Jersey to determine what their good and best practice looks like. Although Dandara Jersey don’t utilise their services a great deal, some of subcontractors do use the services of this agency. It was concluded that this LSA are carrying out due diligence checks to a high standard. In addition, they are part of the government working group on the island that aims to ensure ethical working practices for all workers.	Following a review 2 years ago, we confirmed that the LSA’s appointed by Dandara have good practice checks in place to reduce risk of modern slavery. The risk is further reduced by regular RPO audits. To ensure continuous improvement in this area we will carry out a review of the LSA’s used by our Principal Contractors during FY26 to ensure their compliance checks (right to work, imposter & payroll), etc are robust.
Subcontractors	Subcontractors outsourcing works. Subcontractors not completing their right to work checks properly. Increased construction price of materials placing increased pressure to reduce costs where possible – for example using cheaper labour.	As stated previously, our subcontractors are required to follow modern slavery legislation. We ensure that all sub-contracts in the UK include an electronic copy of our latest Modern Slavery Statement or reference to the Statement on our website. We will continue to require that our subcontractors: Ensure they have a written contract of employment between them and their employees; and Confirm that their employees have not had to pay any direct or indirect fees to obtain work. Our sub-contracts in Jersey also refer to the Dandara Modern Slavery Statement. We are currently reviewing our subcontracts on the Isle of Man to ensure references to modern slavery requirements are included in subcontracts going forward. Over the last year, the HSE team have carried out toolbox training talks on ‘How to spot the signs of modern slavery’ across over 25 of our sites in the UK. Our subcontractors were required to attend these and should now have a good awareness of the key signs and the whistleblowing process. Furthermore, in some UK regions, the HSE team carried out specific modern slavery audits at sites between April and June 2025. The HSE team spoke informally to workers to determine the perceived level of risk at grass roots level. While we have carried out audits of several of our Groundworker Subcontractors, this remains an area of risk – due to the transient nature of some construction workers.	Following a review 2 years ago, we confirmed that the LSA’s appointed by Dandara have good practice checks in place to reduce risk of modern slavery. The risk is further reduced by regular RPO audits. To ensure continuous improvement in this area we will carry out a review of the LSA’s used by our Principal Contractors during FY26 to ensure their compliance checks (right to work, imposter & payroll), etc are robust.

Category

Risk to Dandara

Management and Mitigation Progress during FY25

Continuous Improvement Targets and Next Steps for FY26

Material Suppliers

Using suppliers and sourcing materials from high-risk countries / locations with poor or lack of labour laws.

To mitigate risk, our UK Housebuilding division and Dandara Living carry out modern slavery compliance checks at pre-qualification and during on-boarding process.

We understand that some materials and components such as solar photovoltaics (PV) are supplied from ‘high-risk countries’ represent a significant ethical risk in terms of modern slavery. Previously, an in-depth review of our solar PV supply chain was carried out. The outcome of this is that our Housebuilding division now works with a single PV provider. This PV provider demonstrated the most extensive auditing process (up to Tier 7) to help reduce the risks of modern slavery occurring within the supply chain tiers. This supplier is also a signatory of the Solar Stewardship Initiative (SSI) – a pan-European industry collaboration to increase transparency in the sector.

As per actions identified in our previous Statement due diligence review was carried out into high-risk regions. This review enabled us to:

Identify high-risk regions using tools like the Global Slavery Index; and
Better understand which of the materials and supply chains we utilise are at high risk of labour exploitation using industry reports from the Ethical Trading Initiative.

The outcome of this review is that the housebuilding division PQQ now includes specific mention of certain high-risk regions. Should our suppliers source materials from these regions, it triggers a request for further information. The procurement team then make an informed decision on whether to proceed with this supplier or not.

In our FY24 Statement, the Group committed to developing a Supply Chain Charter. Following engagement with several of our major supply chain partners and a review of best practice charters, we concluded that the principles and requirements commonly set out in such charters are already embedded within our existing governance framework and ESG-related policies. To avoid duplication, the Group will therefore not produce a standalone Charter at this time. Instead, we will strengthen our Sustainable Procurement Policy and develop a standalone Modern Slavery Policy.

The business will review the PQQ process and identify the most appropriate whole supplier engagement and management process.
Work towards establishment of a new supplier engagement and management process / standard across the Dandara Group.
Engage with Certified Suppliers: prioritise partnerships with suppliers who adhere to recognised ethical standards and certifications.
Review and Update sustainable Procurement Policy with particular emphasis on enhancing provisions relating to modern slavery risk (materials / regions).
Stay Informed: Keep up to date of global developments and reports concerning labour practices in high-risk supply chains.
Develop and publish a proportional a Modern Slavery Policy to set out our commitments to enacting practical steps to reduce to risk of modern slavery across our sites.
Refresh our modern slavery information posters across our sites.

Labour Supply Agencies

Risk of labour supply agencies not completing continuous, extensive and robust checks.

To mitigate this risk, an RPO has been appointed and carries out regular audits of LSAs. This helps ensure that and further ensure compliance in relation to modern slavery.

The scope of work for the RPO was extended to cover Jersey during FY25.

In addition, the ESG team held calls with the main LSA on the island of Jersey to determine what their good and best practice looks like. Although Dandara Jersey don’t utilise their services a great deal, some of subcontractors do use the services of this agency. It was concluded that this LSA are carrying out due diligence checks to a high standard. In addition, they are part of the government working group on the island that aims to ensure ethical working practices for all workers.

Following a review 2 years ago, we confirmed that the LSA’s appointed by Dandara have good practice checks in place to reduce risk of modern slavery. The risk is further reduced by regular RPO audits.

To ensure continuous improvement in this area we will carry out a review of the LSA’s used by our Principal Contractors during FY26 to ensure their compliance checks (right to work, imposter & payroll), etc are robust.

Subcontractors

Subcontractors outsourcing works.
Subcontractors not completing their right to work checks properly.
Increased construction price of materials placing increased pressure to reduce costs where possible – for example using cheaper labour.

As stated previously, our subcontractors are required to follow modern slavery legislation.

We ensure that all sub-contracts in the UK include an electronic copy of our latest Modern Slavery Statement or reference to the Statement on our website. We will continue to require that our subcontractors:

Ensure they have a written contract of employment between them and their employees; and
Confirm that their employees have not had to pay any direct or indirect fees to obtain work.
Our sub-contracts in Jersey also refer to the Dandara Modern Slavery Statement.

We are currently reviewing our subcontracts on the Isle of Man to ensure references to modern slavery requirements are included in subcontracts going forward.

Over the last year, the HSE team have carried out toolbox training talks on ‘How to spot the signs of modern slavery’ across over 25 of our sites in the UK. Our subcontractors were required to attend these and should now have a good awareness of the key signs and the whistleblowing process.

Furthermore, in some UK regions, the HSE team carried out specific modern slavery audits at sites between April and June 2025. The HSE team spoke informally to workers to determine the perceived level of risk at grass roots level.

While we have carried out audits of several of our Groundworker Subcontractors, this remains an area of risk – due to the transient nature of some construction workers.

To ensure continuous improvement in this area we will carry out a review of the LSA’s used by our Principal Contractors during FY26 to ensure their compliance checks (right to work, imposter & payroll), etc are robust.

Last year we also identified some general business actions to assist with continuous improvement in reducing risk. These can be summarised as follows:

Communications:

The ESG team leads on liaising with members of the working group.
The HR and HSE teams have reviewed the modern slavery induction and training requirements for office-based and site-staff. This is in the process of being updated and will be rolled out. All staff undergo annual training on the topic.

Key Performance Indicators

We set KPIs on the topic and each year, as part of our continuous improvement attempts, we will review and edit or add new KPIs as necessary.

Table 2:Modern Slavery Mitigation KPI's

No.	Year	KPI	Detail	FY24 Status	FY25 Status
1.	FY24	Develop Vulnerable Persons Procedure.	Vulnerable Persons Standard has been developed to assist teams in their understanding of risk and processes. Guidance is available on the company intranet on how to support vulnerable persons.	Requirement for Procedure / standard was set in FY24	Standard was developed
2.	FY24	Modern Slavery Site Audits	Site audits specifically related to modern slavery were carried out by HSE team	Requirement set in FY24	17 audits were carried out
3.	FY24	Due Diligence Checks of subcontractors (and labour supply agencies)	4 due diligence checks/audits were carried out with our labour Supply Agencies 8 due diligence checks/audits were carried out with Groundworker Subcontractors.	4 LSA audited 8 Ground workers audits	1 subcontractor 2 LSA 2 Suppliers
4	FY25	Number of people attending Modern Slavery Training on site	Data is collated on an ongoing basis.	Requirement set in FY24	27 sessions attended by 287 people

Raising Concerns

There are several ways we encourage those who work with and for us to raise their concerns, based on the level of seriousness. These have been communicated to our colleagues via our intranet and information bulletins across sites within The Dandara Group.

The process includes:

Immediate safeguarding concerns should be reported to the police on 999.
Where modern slavery is suspected but there are no immediate safeguarding concerns, parties should report via the whistleblowing phone number or email address. (Specific contact details have been provided on the intranet & site information poster).
Alternatively, concerns can be reported to the UK’s modern slavery & exploitation helpline on 0800 0121 700 or the Gangmasters and Labour Abuse Authority via 0800 432 0804.

***

This statement is made and published in accordance with Section 54 of the UK Modern Slavery Act 2015 and constitutes the Modern Slavery and Human Trafficking Statement for the financial year ending 30 June 2025.

For the purposes of this statement, references to the Dandara Group mean those companies which meet the reporting threshold under the Act and are subsidiaries of Dandara UK Property Holdings Ltd and Dandara Living Holdings Ltd (as listed above) along with activities carried out on the Isle of Man and Jersey.

This statement has been prepared on behalf of those qualifying subsidiaries. It sets out the steps taken across the group of companies to prevent modern slavery and human trafficking in our operations and supply chains.

The content of this statement was agreed by the Modern Slavery Working Group and will be reviewed and updated annually. Approved by the Boards of Dandara UK Property Holdings Ltd and Dandara Living Holdings Ltd.

*Signed on behalf of those companies and their qualifying subsidiaries:

Steven Hannah

Finance Director

Date: October 2025