Modern slavery statement.

This statement is published in the spirit of the Modern Slavery Act 2015 (“MSA”), section 54. As a newly-formed company in financial year 2026/27, BREE Construction Ltd does not yet meet the £36 million annual turnover threshold that triggers a mandatory statement under section 54. We publish this statement voluntarily, in recognition that:

• our group’s operating entities have been delivering construction in the UK since 1955;
• we are active across build-to-rent, multi-family, affordable, specialist living, student accommodation and land-led delivery, sectors with extended supply chains;
• many of our public-sector and registered-provider clients require evidence of modern-slavery due diligence at procurement;
• transparent reporting is an essential foundation of responsible business.

This is the first statement of BREE Construction Ltd. It covers our activities for the financial year ending 31 March 2027 and will be updated annually.

BREE Construction Ltd was incorporated in 2026 following the management buy-out of the New Homes business of United Infrastructure (formerly United Living New Homes). The group operates a portfolio of construction, development and housing-delivery entities, including operating companies founded in 1955 and 1964.

We are a UK construction contractor, headquartered in Warrington, with active projects across England, Scotland and Wales. Our supply chain comprises:

• design teams (architects, engineers, planning consultants);
• specialist sub-contractors (groundworks, frames, MEP, finishes, façades);
• material suppliers (concrete, steel, timber, fixtures);
• plant and equipment hire;
• logistics, security, welfare and site-services providers;
• professional services (legal, financial, insurance).

We recognise that the construction industry is identified by the Home Office and the Gangmasters and Labour Abuse Authority (GLAA) as a sector with elevated risk of labour exploitation, particularly through layered sub-contracting and the use of agency or migrant labour.

We maintain the following policies relevant to modern slavery:

• Anti-slavery and human trafficking policy. Sets out our zero-tolerance position and applies to all employees, sub-contractors, suppliers and partners.
• Recruitment policy. Confirms direct verification of right-to-work and identity for every BREE Construction employee, with no recruitment-fee charging permitted.
• Whistleblowing policy. Provides a confidential route for employees and sub-contractor personnel to raise concerns about labour practices, with explicit non-retaliation protection.
• Procurement policy. Embeds modern-slavery due diligence into supplier selection and contract terms.

All policies are reviewed at least annually by senior management.

Our due diligence comprises:

• Pre-qualification. Every new sub-contractor and supplier is required to confirm compliance with the MSA and to share any statement they have published.
• Contractual obligations. Our standard sub-contract and supply contracts include modern-slavery and labour-standards clauses, including audit and termination rights.
• Site-level checks. Site managers verify right-to-work documentation for personnel working on BREE Construction projects, regardless of which sub-contractor employs them.
• Reporting routes. Every site has a posted route for raising concerns, including externally to the Modern Slavery & Exploitation Helpline on 08000 121 700.

We assess modern-slavery risk by sector, geography and supply-chain tier:

• Higher risk. Labour-intensive sub-contracted trades (groundworks, demolition, security, cleaning), complex multi-tier supply chains, and materials with known international labour-rights concerns (some natural stone, brick and timber sources).
• Lower risk. Direct-employed personnel, UK-headquartered established suppliers with their own published statements, and design-team consultants.

For higher-risk areas we apply additional scrutiny: more frequent site checks, supplier-statement reviews, and engagement with the Supply Chain Sustainability School.

As a newly-formed entity, we are establishing baseline measures of effectiveness. From financial year 2026/27, we will track:

• the proportion of Tier 1 suppliers who have a published modern-slavery statement (target: 100% for suppliers with statutory obligations, 80% for others);
• the proportion of sub-contracts that include modern-slavery clauses (target: 100%);
• the number of modern-slavery training completions across the workforce (target: 100% of relevant roles annually);
• the number of concerns raised through internal and external reporting channels, and how each was resolved.

These measures will be published in next year’s statement.

Modern-slavery awareness forms part of:

• the BREE Construction induction for every new starter;
• annual refresher training for site management and procurement teams;
• pre-tender briefings for sub-contractors on larger packages.

Training material is updated annually, drawing on guidance from the Home Office, the Construction Industry Council and the Supply Chain Sustainability School.

If you suspect modern slavery or labour exploitation on a BREE Construction project, in our supply chain, or in any business we engage with, please raise it. Routes available:

• Internal. enquiries@breeconstruction.co.uk , confidential review by the Managing Director.
• External. Modern Slavery & Exploitation Helpline: 08000 121 700 (UK, confidential, multilingual).
• Police. 999 if there is an immediate threat to life; otherwise 101.

We will not retaliate against any person who raises a concern in good faith.

This statement was approved by the Board of BREE Construction Ltd on 5 May 2026 and is signed by:

Andrew McDonough
Founder, Owner & Managing Director
BREE Construction Ltd
5 May 2026