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Drumgrange is fully committed to the principles of the Modern Slavery Act 2015.

One of our core values is to uphold sound, responsible and fair business operations. We are committed to promoting and maintaining the highest possible ethical standards in relation to all of our business activities.

As an SME with a turnover of less than £36 million per annum, we are not legally required to make a formal statement. We also have limited resources to wholly guarantee that our supply chain is completely free of modern slavery, including servitude, forced or compulsory labour, labour exploitation and human trafficking. However, we recognise the importance of managing modern slavery risks within our operations and supply chains, and, as such, will maintain proportionate due diligence, supplier governance and reporting arrangements to identify, assess, and manage modern slavery risks. We will take proportionate actions where concerns are identified.

Background & Risk Profile

Drumgrange is a specialised, UK-based company with predominantly domestic suppliers. Procurement activities are focussed on high-specification goods (including specialised hardware and electronic components) and professional services (such as technical consultancy and security-cleared contractors). All procurement activities are conducted seriously, fairly and objectively whilst ensuring that suppliers comply with legal requirements, including financial, health & safety, human rights and labour standards, employment laws and GDPR.

In accordance with the risk assessment principles of the UK Modern Slavery Act 2015, we have the following operational safeguards in place:

1. Highly Skilled Workforce:We rely exclusively on a highly skilled professional workforce. We do not utilise low skilled labour, seasonal workers, or temporary migrant labour, which are statistically vulnerable to exploitation.
2. Right to Work Verification: Robust background checks are conducted on all prospective candidates prior to employment to definitively establish and record their legal right to work in the UK.
3. Security Vetting: Personnel are required to obtain and maintain official UK Government security clearance, providing a rigorous layer of independent secondary vetting.
4. Continued Joint Supply Chain Accreditation Register (JOSCAR) Subscription: Acts as a screening process for suppliers.
5. Training: All employees are informed of potential irregularities to identify counterfeit, bribery and human right act violations, including modern slavery, and mitigate the risk within our supply chain to an acceptable level. Some personnel have completed further modern slavery training, which will help them recognise indicators of modern slavery, address risks within the organisation and supply chains, and understand the relevant reporting procedures or managing suspected cases.
6. Whistleblowing Protection: We support anyone who raises genuine concerns in good faith and no employee will suffer detrimental treatment for reporting a genuine concern.
7. Secure Communication Channels: We have established secure communication channels so that any identified risks of modern slavery can be resolved properly and effectively.

Consequently, the inherent risk of modern slavery within our direct operations and immediate supply chains is assessed as low.

Responsibilities

It is the responsibility of both employees and those involved within the supply chain to adhere to the same principles to ensure all policies, regulatory and statutory obligations are complied with.

Senior Management are responsible for ensuring appropriate controls are implemented and that material risks, incidents or concerns are escalated and managed, with the Board of Directors holding ultimate responsibilit.

Due Diligence

Our risk-based approach to modern slavery and responsible sourcing due diligence includes:

1. Risk Assessment:Systematically identifying and assessing potential modern slavery risks across all business operations and supply networks.
2. Risk Factor Profiling:Evaluating specific risk factors, including sector vulnerabilities, geographical location, labour practices, supplier maturity, contract value, operational criticality, product type, and supply-chain complexity
3. Lifecycle Integration:Embedding modern slavery due diligence seamlessly into supplier onboarding, contract renewals, performance reviews, and general procurement decision-making.
4. Supplier Verification:Utilising targeted supplier questionnaires, formal declarations, policy reviews, evidence requests, and review meetings where appropriate.
5. Contractual Controls:Incorporating explicit, legally binding contractual requirements regarding statutory legal compliance, ethical sourcing, and modern slavery prevention and reporting.
6. Audit and Governance:Retaining comprehensive evidence of supplier due diligence, risk decisions, corrective improvement actions, and escalation records.
7. Continuous Monitoring:Monitoring suppliers on an ongoing basis where specific vulnerabilities are identified, or where customer, contract, or regulatory expectations necessitate enhanced assurance.

Supplier Governance

All procurement activities are conducted seriously, fairly and objectively whilst ensuring that suppliers comply with legal requirements (including financial, health & safety, human rights and labour standards, employment laws and GDPR).

We use a tiered supplier engagement model to support proportionate governance across carbon reduction, responsible sourcing, modern slavery due diligence, ESG maturity and social value reporting.

Tier 1 suppliers will be subject to enhanced modern slavery and responsible sourcing due diligence where relevant. This may include review of supplier policies, supply-chain controls, training arrangements, reporting mechanisms, labour practices, high-risk geographies, high-risk materials and any relevant customer requirements.

Tier 2 suppliers will complete standard modern slavery and responsible sourcing questions as part of onboarding, contract renewal or periodic review.

Tier 3 suppliers will receive proportionate checks and support signposting so that due diligence remains appropriate for SMEs, micro suppliers and niche specialist suppliers.

Tier 4 suppliers will be subject to basic due diligence unless risk, spend, criticality, geography, product type, customer requirements or contract conditions increase the level of review required.

Where concerns are identified, Procurement, the ESG / Environmental Lead and senior management will agree appropriate action. This may include further information requests, enhanced monitoring, corrective action plans, supplier development, suspension of new work or termination of the relationship where necessary.

Approvals

This statement has been approved by the Board of Directors of Drumgrange Limited on 08/10/2026.