Modern Slavery Statement

ORGANISATION

This statement applies to all companies within and associated to Keysource Group (referred to in this statement as ‘The Group’). The information included in the statement refers to the financial year 2024-2025.

ORGANISATIONAL STRUCTURE

The Keysource group consists of five operating companies:

Keysource Limited – Located in the UK and office in Gatwick
GDM Building Consultants Ltd – Located in the UK and office in London, Farringdon
2BM Limited – Located in the UK and office in Beeston, Nottingham
Digital Infrastructure Advisors Limited LLC – Located in USA and office in Reston, Virginia
Keysource Europe UG – Located in Germany and registered office in Frankfurt.

Group employees work at an office location detailed above or at customer sites to deliver customer contract obligations or associated business operations.

The group is controlled by a board of directors including:

Gary Davison, Director
Stephen Whatling, CEO
Jonathan Healy, COO
Simon Thomson, CFO
Warwick Ley, Chairman

The group combines a multidisciplinary team of experts who deliver a complete suite of services and solutions for data centres and critical environments.

The group companies provide three core services to customers:

Consultancy Services
Management Services
Operational Services

Business to Business contracts are agreed to deliver a scope of associated with services. Demand for services are consistent throughout the year and therefore is not seasonal.

The group provides services to customers globally on either a remote working basis or on site, travelling from contracted place of work to project locations.

The labour supplied to the Group in pursuance of its operation is carried out in Europe and USA, with most of the work undertaken in the UK.

DEFINITIONS

The Organisation considers that modern slavery encompasses:

Human trafficking
Forced work, through mental or physical threat
Being owned or controlled by an employer through mental or physical abuse of the threat of abuse
Being dehumanised, treated as a commodity or being bought or sold as property
Being physically constrained or to have restriction placed on freedom of movement.

COMMITMENT

The Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Group understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Group does not enter into business with any other organisation, in the United Kingdom or broad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in UK, USA and countries of customer sites.

SUPPLY CHAINS

In order to fulfil its activities, the main supply chains of the Group include those related to the supply of products and services which support the core services lines at office and customer locations globally.

We understand that some Group first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers

POTENTIAL EXPOSURE

The Group considers its main exposure to the risk of slavery and human trafficking to exist in its supply chains where they involve the provision of labour in a country where protection against breaches of human rights may be limited.

In general, the Group considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it

STEPS

The Group carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Group has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Group has taken the following steps to ensure that modern slavery is not taking place:

Operate an approved supplier list which has undergone the Keysource prequalification process (GSP185).
Manage approved suppliers by the Keysource Supplier Management Procedure (PR161).
This includes adhering to modern slavery supply chain requirements.
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

KEY PERFORMANCE INDICATORS

The Group has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Group or its supply chains.

100% compliance to contractual policy in relation to specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, as per Modern Slavery Policy (POL103)

POLICIES

The Group has the following policies which further define its stance on modern slavery:

Modern Slavery Policy (POL103)
Environment, Social and Governance Policy (POL122)

TRAINING

The Group provides the following training to staff to effectively implement its stance on modern slavery:

Training Module – Modern Slavery (SHARD)

SLAVERY COMPLIANCE OFFICER

The Group has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Simon Thomson, Chief Financial Officer
24th March 2025

Please refer any queries about this policy to the Head of HR.