Modern Slavery Statement

Please see below our approved Modern Slavery Statement published by our parent company, Clece Care Services Ltd.

1: Opening Statement from Senior Management

Clece Care Services Ltd (CCS) is committed to preventing acts of modern slavery and human
trafficking from occurring within its business and supply chain, and imposes the same high standards
on its suppliers.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. At CCS, we
recognise the global impact of slavery and trafficking and as a socially responsible organisation
understand that we have a duty to assist in combating such practices. We are committed to acting
ethically and with integrity in all business dealings and we have created effective systems and
controls to safeguard modern slavery taking place within our business or our supply chain.

 

2: Structure of the Organisation, its Business and Supply Chains

This statement should be considered the Modern Slavery statement for CCS and all companies within
the UK Group, whether wholly or partially owned by CCS or any of its subsidiaries.

CCS is a company registered in England and Wales. Its parent company, Clece S.A. is incorporated
in Spain. Our ultimate parent entity is ACS Actividades de Construcción y Servicios S.A (‘ACS’), also
incorporated in Spain. The total number of companies including CCS, within the UK Group are as
detailed at Annex 1. Whilst ACS has been in existence for over two decades, CCS commenced its
operations in the UK in 2013.

Our primary business is the service of delivering care to the vulnerable in our society. We are a group
of regional care companies providing predominantly domiciliary care services across the UK, with
contracts mostly being with Local Authorities and the NHS. We also have an airport division.

 

3: Policies

As part of our commitment to combating modern slavery, we have implemented an Anti-Slavery
Policy. We also make sure our suppliers are aware of our policies, and seek to ensure they adhere to
the same high standards.

 

4: Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within
our supply chains, we have adopted a number of procedures and continue to review our processes
and best practice guidance with a view to:

• Identifying and assessing areas of potential risk in our business and supply chains
• monitoring potential risk areas in our business and supply chains
• reducing the risk of slavery and human trafficking occurring in our business and supply chains
• providing adequate protection for whistleblowers

 

5: Risk and Compliance

CCS regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring
in its supply chain.

We do not consider that we operate in high risk sectors or locations because the majority of our staff
and suppliers are based in the UK.

Where we identify a potential risk, these will be investigated, remediated and mitigated through
activities such as due diligence, improved procurement and recruitment practices or industry
collaboration.

We seek to ensure all our suppliers adhere to our anti-slavery policy. We enforce a strict code of
compliance and do not tolerate slavery and human trafficking within our supply chains. For example, if
we found evidence of concerning practice which fails to meet with our policies we would seek to
rectify the concern or refuse to contract with that party or would terminate our relationship with the
relevant supplier.

 

6: Training

We invest in educating our senior staff, recruitment and procurement teams to recognise the risks of
modern slavery and human trafficking in our business and supply chains. Through our training
programmes and other communication channels employees are encouraged to identify and report any
potential breaches of the organisation’s Anti-Slavery Policy. Employees are taught the benefits of
stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to
eradicate slavery and human trafficking from our business and supply chains.

 

7: Further Actions and Sign-off

The Company remains committed to preventing slavery or human trafficking from occurring in our
business or supply chains and we intend to continue to strive to improve and strengthen the existing
safeguards we have in place.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and
constitutes CCS’s Modern Slavery Statement for the financial year ending 31 December 2023. The
board of CCS and its subsidiaries listed in Annex 1 have approved this statement.

Signed by

Miguel Angel Herraiz Marco
Chief Executive Officer
Clece Care Services Ltd

Date: 22/08/2024