Modern Slavery Act 2015:

Anti-Slavery and Human Trafficking Statement 2020

INTRODUCTION FROM THE CHIEF EXECUTIVE OFFICER

This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It sets out the steps taken by FCC Environment (UK) Limited and its subsidiaries; FCC PFI Holdings Limited, FCC Environment Services (UK) Limited and Telford & Wrekin Services Limited, together known as “FCC Environment” to prevent modern slavery and human trafficking in its business and supply chain. For a full list of company subsidiaries please see the attached 2021 company list.

FCC Environment published its first Anti-Slavery Statement in November 2016. In this past year we have continued to increase our awareness of modern slavery by continuing our staff education programme and enhancing the education on our operational sites.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to seek to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and, as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

Slavery and human trafficking is a growing problem, and only by being vigilant as a company can we hope to try to tackle this. We understand that complicated supply chains pose the greatest risks for vulnerable workers and therefore this is where our greatest efforts have been and continue to be concentrated.

ORGANISATION’S STRUCTURE

FCC Environment is one of the UK’s leading and resource management companies providing a range of services from collecting business and municipal waste to and processing and the generation of green energy from waste. We minimise the amount of waste that ends up in by transforming it into valuable resources.

FCC Environment is a key player within the municipal sector, and we hold over 100 contracts with some 60 local authority clients across England, Wales and Scotland.

We provide a diverse range of cost effective and sustainable waste processing, recycling, treatment, disposal and energy recovery services for local authority and private commercial customers. Annually, FCC Environment receives, treats, recycles and disposes of approaching 10 million tonnes of household, commercial and and manages around 280 waste management facilities, and produces over 117MW of energy. Through innovative solutions, FCC Environment is committed to working with its local authority partners and industrial and commercial customers to respond to often complex and far- reaching waste management strategies, to meet the challenges of increased regulation, and to improve upon waste management targets.

FCC Environment is a part of the FCC group, and our ultimate parent company is Fomento de Construcciones y Contratas, S.A. (“FCC”). FCC is a significant multi-national business with operations in Europe, South and Central America, Africa, the Middle East and the United States of America. FCC’s principal activities cover Environmental Services (including waste management), Construction, Cement and Infrastructure. The FCC group has accumulated 125 years of experience delivering services to citizens all over the world operating in 35 countries.

OUR BUSINESS

FCC Environment’s business in the UK comprises the following business activities:

 Recycling – comprising mechanical treatment plants, composting and household waste recycling centre, operations as well as several limestone quarries in Yorkshire;  Green Energy – which manages EfW plants at Eastcroft in Nottingham (producing steam for the UK’s largest district heating scheme), at Allington in Kent, Greatmoor in Buckinghamshire and North Hykeham in Lincolnshire (producing electricity for export).  In 2019 our new plant in Scotland entered into the services period of the contract delivering a waste solution for the Partner Councils the City of Edinburgh and Midlothian. The new plant has the capacity to accept 159,000 tonnes per annum comprising of up to 135,000 tonnes from the Partner Councils with the remainder secured through securing additional waste from other councils or the commercial market. The plant is exporting approximately 13 MW of electricity which is enough to provide power to 32,000 households and businesses.

 Waste Processing – comprising transfer station, landfill, treatment (including solid and liquid ) and clinical waste solutions; and  Business Waste Solutions – which has UK responsibility for the collection of commercial and industrial and healthcare waste from FCC Environment’s business customers. This is to support the existing and planned infrastructure of the Recycling and Waste Processing activities.

FCC Environment is committed to maintaining the highest ethical standards, and seek to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our anti-slavery policy reflects our commitments to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

OUR VALUES AND BEHAVIOUS

At FCC Environment we have a vision for how we want our company to develop and grow and we want our company to be shaped by the values we hold and the people we work with, as we all work towards the same goal. This starts with how we treat our employees, our colleagues and our customers.

 Environmental Commitment; being environmentally and socially responsible in the services we provide

 Forward Thinking; embracing change and preparing for the future

 People Focus; valuing, rewarding and praising our teams, motivating others and enjoying the work we do

 Doing the Right Thing: building a successful and secure future by being customer focused and delivering quality services.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

We have undertaken due diligence checks of all suppliers in the form of ethical/compliance questionnaires and audits. We are committed to improving practices and we have in place systems to:

 Identify and assess potential risk areas in our supply chains.  Mitigate the risk of slavery and human trafficking occurring in our supply chains.  Monitor potential risk areas in our supply chains.  Protect whistle blowers.

SUPPLIER ADHERENCE TO OUR VALUES

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and our contractors comply with our values, ethics and policy, we have in place a supply chain compliance programme.

All suppliers (new and existing) must confirm conformance to our Code of Conduct and policy or, alternatively, confirm that they have policies of their own with which they comply.

TRAINING

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have provided awareness training to all our staff. All supervisors and managers are regularly trained to ensure they are aware of the signs of slavery and to advise them of the actions they should take should they suspect modern slavery exists.

In 2020 a series of Toolbox Talks took place on all our sites, by the site managers. This refreshed the earlier training ensuring the message was clear staff aware on how to recognise modern slavery and what actions to take if recognised.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

We use the following key performance indicators (KPIs) to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:

- We understand that modern slavery risk is not static, and we will continue to seek to mitigate the risks in the years ahead. - We will assess the effectiveness of the measures being taken by monitoring, inter alia, staff training, supply chain audit and verification and investigations into reports of modern slavery.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes FCC Environment (UK) Limited’s anti-slavery and human trafficking statement.

Paul Taylor Chief Executive Officer FCC Environment (UK) Limited

Date: 19 March 2021 2021 Company List Company Registered Number Azincourt Investments, S.L. FC031616 FCC Environment (UK) Limited 2902416

3C Holdings Limited 3610048 3C Waste Limited 2632581 WRG Waste Services Limited SC23357 Allington Waste Company Limited 4792815 Allington O&M Services Limited 2464345 Anti-Waste (Restoration) Limited 2993753 Anti-Waste Limited 1569257

Arnold Waste Disposal Limited 930757 BDR Property Limited 2250123

BDR Waste Disposal Limited 2692495 Darrington Quarries Limited 579409 Derbyshire Waste Limited 2666323 East Waste Limited 2629972 FCC Environmental Services Limited 1567453 Finstop Limited 3188850 FCC Environment Limited 2830895 Hykeham O&M Services Limited 7418624 Integrated Waste Management Limited 2433703 Kent Conservation & Management Limited 4045661 Kent Energy, Ltd 3146731 Kent Enviropower Limited 2894377 Landfill Management Limited 2069821 Lincwaste Limited 2668959 Norfolk Waste Limited 3001490 Focsa Services (U.K.) Limited 2693394 Pennine Waste Management Limited 3057012 Shelford Composting Limited 3968180 T.Shooter Limited 2008873 Waste Recovery Limited 2411841 Waste Recycling Group (Central) Limited 4000033 Waste Recycling Group (Scotland) Limited SC210275 Waste Recycling Group (Yorkshire) Limited 2436946 FCC Recycling (UK) Limited 2674166 WasteNotts (Reclamation) Limited 2674169 WasteNotts O&M Services Limited 2629246 Welbeck Waste Management Limited 2736095 FCC Environment (Lincolnshire) Limited 7418620 Waste Recycling Group (UK) Limited 2563475 WRG (Midlands) Limited SC43286 WRG (Northern) Limited SC98678 WRG Acquisitions 2 Limited 5056437 FCC Environment (Berkshire) Limited 5663735 WRG Environmental Limited 2206141 FCC Waste Services (UK) Limited 988844 FCC Energy Limited 11338743 FCC Environment Lostock Limited 11781645 Enviropower Investments Limited 5024248 FCC PFI Holdings Limited 5567306 RE3 Holding Limited 5663732 RE3 Limited 5663734 FCC Wrexham PFI Holdings Limited 5567332 FCC Wrexham PFI Limited 5572555 FCC Wrexham PFI (Phase II Holding) Limited 8164670 FCC Wrexham PFI (Phase II) Limited 8164693 FCC Buckinghamshire Holdings Limited 7775848 FCC Buckinghamshire Limited 7776674 FCC Buckinghamshire (Support Services) Limited 8255628 FCC Lostock Holdings Limited 11781540 Green Recovery Projects limited 12749606 FCC Energy Holdings Limited 12763603 Green Eneregy Finance Solutions Limited 12763575 FCC Environment Developments Limited 10325758 FCC (E&M) Holdings Limited 10326352 FCC (E&M) Limited 10327359 FCC Environment Services (UK) Limited 2375726

Telford & Wrekin Services Limited 4088472