MODERN SLAVERY ACT 2015: SLAVERY AND HUMAN TRAFFICKING STATEMENT

We are committed to improving our practices to combat slavery and human trafficking through our Anti-Slavery policy, as well as the constant efforts of all involved within the Group.

SigmaRoc plc’s structure, business, and supply chain

• SigmaRoc plc is an AIM quoted company that invests, improves and integrates companies within the construction materials space in the United Kingdom and Europe.

• The SigmaRoc Group has c.1,000 employees and comprises multiple subsidiaries that operate under it in England and Wales, the Channel Islands and Belgium. They provide a variety of asphalt, aggregates, cement, concrete, and natural stones products and services through the operation of their own and third party assets. The Group has a global annual turnover of over £120 million for Financial Year 2020.

  • • As an integrated business, our supply chain covers the United Kingdom and Europe and includes the delivery of products and services across those regions and occasionally beyond. In terms of suppliers, we primarily engage with those in these regions, particularly with raw materials such as cement, bitumen and operational machinery.

Our policies on slavery and human trafficking

• 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 Anti-Slavery policy reflects our commitment to act ethically and with integrity in all our business relationships and to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

• We have also implemented a Human Rights and Community policy, as well as a Health & Safety policy, both of which support our efforts to provide a safe working place free of abuse. Our Whistleblowing policy ensures any incidents or abuses can be reported through alternative channels.

Due diligence processes for slavery and human trafficking

• The Group frequently reviews its suppliers for adherence to our values and alignment with our policies. We strive to keep our supply chain as local and simple as possible, prioritising working directly with trusted and regular suppliers.

Assessment and management of slavery and human trafficking risks

• The Group operates within the United Kingdom, the Channel Islands, and the European Union, and as a result its supply chain is predominantly located there as well, where companies operate within the bounds of robust local labour and human rights protection.

• Following several acquisitions in England and Belgium in 2019 and 2020, the Group has been working to assess where the risks regarding modern slavery and human trafficking lie in its direct activities and through 202103 Anti-Slavery Statement FINAL 2

its supply chain. Similarly, we have been implementing and reviewing their standard purchase conditions to include respect for human rights and anti-slavery dispositions.

Training

• Senior management, as well as local human resources and procurement staff are provided with ongoing training on the requirements of the Modern Slavery Act 2015.

• In addition, we expect all personnel to comply with the Anti-Slavery, Human Rights and Community as well as Health and Safety policies. Incidents and abuses can be reported to local and senior management, and to our Group Whistleblowing and Compliance Officer in accordance with our Whistleblowing policy.

Our effectiveness in combating slavery and human trafficking

• The Group has been acquiring companies across the United Kingdom and Europe at a steady pace in recent years, and as such has worked diligently to devise, implement, and review policies across all local companies, including our Anti-Slavery, Human Rights and Community, Health and Safety as well as Whistleblowing policies.

• These policies and their effectiveness in addressing issues of modern slavery and human trafficking will be reviewed at least annually, to ensure the Group is consistent and efficient in its efforts. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the 2021 financial year. It was approved by the board on 12 April 2021.

Max Vermorken

SigmaRoc plc