MODERN SLAVERY STATEMENT

1^st April 2025 – 31^st March 2026

1. Introduction

1.1 This statement sets out NY Highways actions to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our own business or our supply chains. This statement relates to actions and activities during the financial year 1 April 2025 to 31 March 2026.

1.2 As an employer and purchaser of a wide range of goods related to Highway maintenance in the United Kingdom, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.

1.3 NY Highways are absolutely committed to preventing slavery and human trafficking in our corporate activities and to ensure that our supply chains are also free from slavery and human trafficking in line with Clause 54 of the 2015 Modern Slavery Act and subsequent government guidance and best practice.

2. Modern Slavery Act 2015
3. Our organisation’s structure, our business and our supply chains

NY Highways was established as a “Teckal” company to provide highway services to North Yorkshire  Council (NYC).  We provide highway services across North Yorkshire that deliver planned and emergency highways and streetlight repairs, winter maintenance schemes, road and infrastructure construction, owned and client fleet maintenance.  We remain vigilant to the risk of slavery and human trafficking and will manage any risks presented.

From an organisational perspective, it is recognised that modern slavery is a crime that is prevalent within the UK, across many industries and as such, it is a risk that NY Highways takes seriously. However, rather than this risk being looked at in isolation, modern slavery is managed alongside a range of other risks that must be dealt with as part of our business activities e.g. implementing responsible procurement, health and safety etc.

Modern slavery can affect people of any age, gender, ethnicity or nationality; however, vulnerable or ethnic minority groups may be more vulnerable to exploitation.

It can take many forms, including forced labour, debt bondage, domestic servitude, criminal exploitation and human trafficking. Victims may be subjected to poor working conditions, threats, intimidation or coercion.

Where people may be subject to sexual or domestic exploitation or abuse, forced to work long hours for little or no pay in poor conditions under verbal or physical threats of violence to them or their families or subject to criminal exploitation.

We have determined that there is potential for an area of risk in the groups of men or women hired to work in small groups as manual labour, but we are confident the recruitment and procurement processes we have in place greatly reduce this and we are alert to the potential high risk of slavery or human trafficking.

3.2 Our Organisation

NY Highways recognises that the risk of modern slavery is not uniform across all areas of its operations and supply chains. Whilst the organisation considers the risk within its directly employed workforce to be low due to established recruitment, payroll and employment practices, there remains a potential risk within sectors that rely upon temporary labour, subcontracting arrangements and supply chains extending beyond the United Kingdom.

Areas identified as carrying an increased potential risk include:

• Temporary and agency labour.
• Construction and highways subcontractors.
• Supply chains for construction materials, plant, equipment and personal protective equipment (PPE).
• Other labour-intensive services where there may be limited visibility of employment practices further down the supply chain.

To mitigate these risks, NY Highways apply  fair and robust recruitment practice and pay and conditions.  We have a single status pay structure with incremental progression through the grades. The basic pay rate will vary between posts but all employees have access to the same ‘benefits’; sick pay, pension, holidays etc. Everyone will be paid an annual salary, divided into 12 equal monthly payments, so they know what to expect, winter and summer, working or on leave.

3.3 Our Supply Chains

NY Highways continues to incorporate modern slavery considerations into procurement and contract management activities. Procurement is a centralised function, directly responsible for procurement of all contracts worth £100,000 or more. Provided best value can be demonstrated or quotes are sourced, the NY Highways Buying Team and individual departments have the scope to award contracts worth less than £100,000, with support available from North Yorkshire Council’s (NYC) Procurement and Contract Management Service if required.

Contract management is split between the Commercial Team, Buying Team and other service areas. NYC’s Procurement and Contract Management Service provide information, support and resources to support contract management across the organisation. NYH utilise a Dynamic Purchasing System (DPS) to cover a comprehensive range of highways related services and products, in partnership with Constructionline.

NY Highways currently has an annual turnover in the region of £86 million.  The Procurement and Contract Management Service take the lead on tackling modern slavery in our supply chains, although there is recognition that responsibility and effort permeates and extends throughout the organisation, particularly in those areas more susceptible to modern slavery. Suppliers appointed through formal procurement processes are required to comply with all applicable legislation. Where appropriate, suppliers are asked to demonstrate the steps they take to prevent modern slavery and human trafficking within their own operations and supply chains.

Much of our effort to date has focused on laying the foundations in order to simply and practically build the prevention, identification, and mitigation of modern slavery into all aspects of the procurement and contract management lifecycle. The Procurement and Contract Management Service’s transition to a category management model helps our procurement professionals to develop expertise, supplier relationships and understanding of particular markets. A comprehensive contract management toolkit helps to embed best practice across NY Highways, to ensure that a standard and robust approach is taken to monitor supplier performance.  Our procurement and contract procedures can be found here.

We act in full accordance with the Modern Slavery Act 2015 and the requirements under the

Procurement Act 2023 but we know that we can and must do more.

NY Highways will continue to develop and strengthen its approach to identifying, preventing and mitigating modern slavery risks within its operations and supply chains, reviewing arrangements annually and implementing improvements where required.

4. Our policies in relation to slavery and human trafficking

We review our policies and procedures to ensure they remain compliant and fit for purpose. The following policies and procedures are key in meeting the requirements of the Modern Slavery Act 2015.

4.1 Recruitment

For the recruitment of permanent staff we have implemented an outsourced recruitment platform with North Yorkshire Council to standardise our approach to recruitment

They include robust procedures for vetting new employees, which ensures they are able to confirm their identities and qualifications.  To comply with the Asylum, Immigration and Nationality Act 2006, all prospective employees supply original documents as evidence of their eligibility to work in the UK, which is verified as original.  Where required evidence of valid driving licences and the relevant categories are checked.  References are requested directly and we do not accept references provided upfront by a potential employee.

4.2 Agency Workers

For temporary agency staff, a neutral vendor is used.  Agencies signed up to this comply with the Modern Slavery Act 2015 and agree to NY Highways terms, conditions and negotiated rates. Agencies submit candidates for a role along with identification documents and references for agency workers; this helps us ensure that the person introduced by the agency is the person completing the assignment and we have transparency in the payment of agencies and agency workers.

4.3 Pay

As part of our SLA with North Yorkshire Council we operate a Job Evaluation Scheme to ensure that all employees are paid fairly and equitably in an agreed pay framework. Equal pay is evaluated and governed by the HR service in partnership with trade unions.

4.4 Employee Code of Conduct

Our Employee Code of Conduct makes clear to employees the actions and behaviours expected of them when representing NY Highways.  We strive to maintain the highest standards of employee conduct and ethical behaviour and breaches are investigated and appropriate action taken.

4.5 Whistleblowing

We encourage all our employees, customers and other business partners to report any concerns related to the direct activities or the supply chains of NY Highways.

5. Staff Training and Learning:

To ensure effective and proportionate training for our operational context, NYHighways delivers dedicated Modern Slavery Toolbox Talks to all employees who may come into contact with vulnerable individuals or situations where exploitation may be present. These Toolbox Talks cover the key indicators of modern slavery, the responsibilities of employees, and the internal and external processes for reporting concerns as well as identifying concerns in supply chains.The training is reiterated through the availability of the Toolbox Talk materials on the NYHighways intranet, enabling staff to revisit the information at any time and ensuring ongoing awareness across the organisation. This approach ensures that NYHighways continues to meet its legal and ethical obligations by providing accessible and relevant training that supports early identification and appropriate escalation of potential modern slavery concerns. A record is maintained of all employees based in the Commercial and Buying Team who have completed the Toolbox talks during 2025/26.

6. Monitoring and evaluating

Responsibility for modern slavery compliance rests with the Commercial Team, supported by Procurement and HR, with oversight provided by the NYH Board of Directors.

During 2026/27 NY Highways will continue to:

• Promote awareness of modern slavery amongst employees.
• Monitor any concerns or allegations received.
• Consider modern slavery risks within procurement and contract management activities.
• Work with suppliers and partners to encourage ethical employment practices.
• Review this statement annually.

7. Approval

This statement has been approved in August 2026 and it will be reviewed and updated annually. Published September 2026. This statement will be published on our website and uploaded to the UK Government Modern Slavery Registry.

Jamie Crumlish

Managing Director

NY Highways