Modern Slavery Statement

1. Introduction

KAB Projects is committed to preventing modern slavery and human trafficking in its own business and in its supply chains, and to acting ethically and with integrity in every relationship it holds. This statement sets out the steps we take, and is made in the spirit of section 54 of the Modern Slavery Act 2015.

2. Why we publish this voluntarily

Supplying labour into offshore projects, through layered subcontracting and across borders, is exactly the kind of supply chain in which forced labour and exploitation arise. Being small is a reason to be more careful, not a reason to say less. Our clients increasingly expect a published position, and we would rather set one out plainly than answer it a questionnaire at a time.

This statement covers the financial year ended 31 July 2026 — the company's first financial period, running from incorporation on 16 July 2025 — and applies to K A B PROJECTS (NW) LTD and all of its trading activity.

3. Our business and supply chains

KAB Projects is a specialist recruiter placing electrical, high-voltage and mechanical engineers into offshore wind and M&E construction projects. We operate as an employment agency for permanent placements and as an employment business for contract and temporary supply.

Our supply chain is short but not simple. It consists of:

• Work-seekers we place directly, in the UK and internationally;
• Umbrella companies and payroll intermediaries through which some contractors are engaged and paid;
• Clients, principal contractors and their subcontractors, where our workers sit inside a wider site workforce we do not control; and
• Business suppliers — software, professional services, training providers.

4. Where we think the risk sits

We have assessed our exposure as concentrated in four places:

5. Due diligence and controls

• Right-to-work checks. We verify every worker's legal right to work using the prescribed methods, and keep the statutory record. This is a key control against forced and illegal labour, not a box-ticking exercise.
• No fees to work-seekers, ever. We never charge a work-seeker a fee for finding or seeking to find them work. This is required by the Employment Agencies Act 1973, and charging workers to work is one of the clearest markers of exploitation.
• Direct engagement with candidates. We deal with work-seekers ourselves rather than through unvetted introducers, and we are alert to the indicators — a third party speaking for the worker, pay directed to an account in someone else's name, identity documents held by another person, reluctance to talk unaccompanied, or several workers sharing one address or phone number.
• Intermediary checks. We assess umbrella companies and payroll intermediaries before we work with them, and we look at how workers are actually paid and what is deducted, not only at the contract.
• Worker welfare on cross-border postings. Where we mobilise workers internationally we check accommodation standards, that pay meets host-country rates rather than a bare minimum, and that the required notifications have been made.
• Terms of business. Our client and supplier terms require compliance with the Modern Slavery Act 2015 and permit us to end an arrangement where we find exploitation.

6. Supporting policies

This statement sits alongside our internal Anti-Bribery and Corruption Policy, Equality, Diversity and Inclusion Policy, Health and Safety Policy, Whistleblowing Policy and our compliance standard operating procedures covering right-to-work verification and international mobilisation. Copies are available to clients on request.

7. Training and reporting concerns

Everyone at KAB who deals with work-seekers is made aware of the indicators of modern slavery and of how to raise a concern. Concerns are escalated to a director immediately and, where appropriate, reported to the police or to the Gangmasters and Labour Abuse Authority. A worker, a member of staff or a member of the public can raise a concern with us directly at admin@kabprojects.com, and can do so without giving their name.

If you believe someone is in immediate danger, call 999. The Modern Slavery & Exploitation Helpline is available around the clock on 08000 121 700.

8. Measuring effectiveness

We are a young business, and we would rather say so than claim a track record we do not yet have. For the period covered by this statement we measure ourselves against four things:

• the proportion of placed workers for whom a compliant right-to-work check is on file — our target is 100%;
• the proportion of umbrella and payroll intermediaries in use that have been assessed before first use — our target is 100%;
• the number of concerns raised, and what happened to each; and
• the number of client and supplier contracts carrying modern slavery obligations.

9. What we are doing next

• Extending our written intermediary assessment into a standing annual re-check rather than a one-off at onboarding.
• Adding modern slavery awareness to the induction every new consultant completes, with a record kept.
• Asking our clients for visibility of the labour tiers our workers sit alongside on site.

10. Approval

This statement was approved by the board of K A B PROJECTS (NW) LTD and is reviewed and re-approved annually, or sooner if the law or our business changes.