Modern Slavery & Human Trafficking Statement

Voltarra Group is committed to conducting business responsibly and with respect for human rights. We do not tolerate slavery, servitude, forced or compulsory labour, human trafficking, child labour or other forms of exploitation within our operations or supply chain.

We seek to identify, prevent, mitigate and, where necessary, remedy modern slavery risks in a manner proportionate to the nature, location and complexity of our activities.

This statement is published voluntarily. It does not represent that any Voltarra entity is currently required to publish a statement under section 54 of the UK Modern Slavery Act 2015.

This statement applies to Voltarra Group AG and the entities it controls, together referred to as Voltarra Group. It applies to directors, employees, consultants and temporary workers, and sets the standards expected of suppliers, subcontractors, labour providers and other delivery partners working under Voltarra's management or control.

Voltarra provides design, engineering, construction management, fit-out, critical-infrastructure upgrade, testing and commissioning services across Europe. Our supply chain includes professional advisers, architects, engineers, specialist consultants, subcontractors, manufacturers, equipment suppliers, logistics providers and labour providers.

We recognise that construction and engineering supply chains can contain several tiers and that visibility can reduce further down those chains. Our controls therefore focus on the areas where the nature of the work, labour model, country, product or lower-tier structure creates a heightened risk.

Modern slavery risk is considered as part of proportionate supplier, subcontractor and project review. Particular attention is given to the following areas:

Labour:. Agency, temporary, migrant or subcontracted labour; recruitment fees; document retention; wage and working-time practices; and worker freedom to leave employment.

Lower-tier supply chain:. Use of unapproved subcontractors, limited visibility below the first tier, unclear legal identity or ownership, and weak evidence of competence or labour controls.

Equipment & materials:. Products or components sourced through complex manufacturing chains, high-risk categories, or locations where labour practices may be less transparent.

Project conditions:. Programme, cost, access or production pressure; remote or transient workforces; language barriers; and work in jurisdictions requiring additional local review.

Freely chosen work:. Work must be freely chosen. Forced, bonded, indentured, trafficked or prison labour used unlawfully is prohibited.

Recruitment:. Workers must not be charged inappropriate recruitment fees or required to surrender identity or travel documents as a condition of work.

Child labour:. No person may be employed below the applicable legal minimum age. Young workers must be protected from hazardous or prohibited work.

Pay & conditions:. Pay, working time, rest, leave, accommodation and employment conditions must comply with applicable law and contractual requirements.

Freedom & dignity:. Workers must be free from violence, coercion, threats, harassment, discrimination and degrading treatment, and free to leave employment subject to lawful notice.

Transparency:. Legal identity, labour arrangements, lower-tier subcontracting and relevant concerns must be disclosed accurately when requested.

Reporting:. Suspected exploitation or material non-conformance must be reported promptly and investigated without retaliation against a person raising a concern in good faith.

The depth of due diligence is proportionate to the scope and assessed risk. Before appointment, Voltarra may review:

• Legal identity, ownership, registrations, insurance and enforcement history
• Relevant experience, competence, health and safety performance and management arrangements
• The proposed labour model, use of agencies and use of lower-tier subcontractors
• Modern slavery, human-rights or ethical-supply-chain policies and declarations
• Country, category and product risks associated with the appointment
• Any adverse information, unresolved concerns or inability to provide credible evidence

Where proportionate, Voltarra will include ethical labour and modern slavery expectations in appointment, procurement or contractual documentation. Suppliers and subcontractors are expected to apply equivalent standards to the organisations and workers they engage, maintain appropriate records, cooperate with reasonable review and notify Voltarra of a material concern or breach.

Voltarra may require corrective action, additional evidence, monitoring or approval before lower-tier subcontracting. A failure to meet the required standard may affect appointment, continued engagement or future tendering.

Employees, consultants, workers, suppliers and other stakeholders are encouraged to report suspected modern slavery, trafficking, forced labour or labour exploitation through their normal Voltarra contact, project reporting route or the contact channel published on the Voltarra website.

A concern raised in good faith will be considered seriously and handled as sensitively as circumstances allow. Retaliation against a person who raises a genuine concern or assists an investigation is not acceptable.

Voltarra will assess concerns promptly and obtain competent legal, safeguarding or specialist advice where required. The response will be proportionate to the evidence, potential harm and immediate risk to affected people.

Actions may include protecting a worker from immediate danger, preserving confidentiality, requiring corrective action, increasing monitoring, suspending work, withholding approval, terminating a relationship or reporting a matter to the appropriate authority. Decisions will take account of the risk that an abrupt commercial response could unintentionally place affected workers at greater harm.

Voltarra will provide proportionate awareness and training for roles involved in procurement, project delivery and supply-chain management. Training will focus on indicators of exploitation, recruitment and labour risks, escalation routes, evidence requirements and a victim-centred response to concerns.

Voltarra will develop and review measures appropriate to the scale and maturity of its operations. These may include:

• Completion of supplier and subcontractor prequalification
• Ethical-supply-chain or modern slavery confirmations received
• Training completed by relevant roles
• Concerns raised, investigated and closed
• Corrective actions, audit findings and repeat non-conformances
• Improvements made to procurement, contractual and lower-tier controls

The Board retains responsibility for this statement. It will be reviewed at least annually and earlier following a material change in the business or supply chain, entry into a new market, a significant concern, relevant legal change or assurance identifying that the current controls are no longer effective.

If a Voltarra entity becomes subject to a statutory reporting requirement, the Group will review the applicable reporting period, approval, publication and registry requirements and issue the required annual statement within the prescribed timeframe.