Modern Slavery Statement

1. Introduction

This statement is made on behalf of Hearne Holmes Developments Ltd pursuant to section 54(1) of the UK Modern Slavery Act 2015 and sets out the steps we have taken and are continuing to take to ensure that modern slavery and human trafficking are not taking place within our business or supply chains.

Hearne Holmes Developments Ltd is committed to maintaining the highest ethical standards and ensuring that all aspects of our operations are free from slavery, servitude, forced labour, and human trafficking.

2. Our Business

Hearne Holmes Developments Ltd is a UK-based property development company specialising in the design, planning, and construction of residential and mixed-use developments. We work with a wide range of suppliers, contractors, subcontractors, and professional consultants throughout the property development lifecycle.

3. Our Supply Chains

Our supply chains include:

· Construction contractors and subcontractors

· Materials and equipment suppliers

· Architectural and design service providers

· Legal, financial, and professional advisory services

· Facilities and site management services

We recognise that the construction sector, due to its complex subcontracting practices and reliance on manual labour, is particularly vulnerable to modern slavery risks.

4. Our Policies

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our relevant internal policies include:

· Anti-Slavery and Human Trafficking Policy – outlines our stance and procedures for identifying and addressing modern slavery.

· Code of Conduct – sets expectations for ethical behaviour from our employees and contractors.

· Whistleblowing Policy – encourages staff and third parties to report any concerns, including those related to modern slavery, without fear of retaliation.

5. Due Diligence

We undertake appropriate due diligence when engaging new suppliers or contractors. This includes:

· Risk assessments based on the nature and location of the service

· Requiring compliance with our Anti-Slavery Policy

· Conducting supplier audits (where appropriate)

· Inserting contractual provisions to ensure ongoing compliance with modern slavery laws

6. Risk Assessment and Management

We assess the risk of modern slavery across our operations and supply chains based on the sector, geography, and type of service. Particular focus is placed on areas involving low-skilled labour, subcontracted services, or overseas sourcing.

7. Training and Awareness

We are committed to raising awareness of modern slavery among our staff. We provide training to relevant employees on how to:

· Identify potential signs of modern slavery

· Report concerns internally or externally

· Ensure ethical labour practices are upheld in their areas of responsibility

9. Our Commitment

Hearne Holmes Developments Ltd will continue to monitor and improve its practices to ensure that modern slavery has no place in our business or supply chains. We expect our employees, suppliers, and partners to share our commitment to ethical conduct and human rights.

10. Approval

This statement was approved by the board of directors of Hearne Holmes Developments Ltd on 07.10.2025.