Modern Slavery and Human Trafficking Statement

Year to 31 December 2025

This slavery and human trafficking statement (the “Statement”) is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 (the “Act”) and covers the activities of Brockton Everlast Inc. Limited (“Brockton Everlast”, “us”, “we”, “our”) and all of its subsidiaries. This annual statement outlines the steps that we are taking to prevent modern slavery and uphold ethical standards in all aspects of our business. Our statement is reviewed and published annually on our website www.brocktoneverlast.com.

Brockton recognises that modern slavery is a crime and a severe violation of fundamental human rights.  It takes various forms in addition to slavery, such as servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another for the purposes of exploitation for personal or commercial gain.

We recognise our responsibility to respect human rights throughout our operations and supply chains.  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 ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

As at the date of publication, no incidents of modern slavery have been identified or reported in our business or supply chain.

Brockton Everlast is a London-based real estate investment and development firm with a focus on acquiring, managing and developing large-scale, best-in-class workspace and science and innovation buildings across London, Oxford and Cambridge.  Our investment strategy prioritises sustainable, innovative and strategically located buildings that support the evolving needs of businesses, research institutions and the local communities in which we operate.

We recognise our responsibility to maximise the social impact of our buildings and business on the local communities.  These initiatives range from our partnership with Access Aspiration – Mayor’s Fund for London, to provide work experience and training to teenagers from low-income and under-represented backgrounds to once complete, using excess energy generated by the Dovetail Building to heat the nearby Middlesex Estate, enabling people living on the estate to get free heating and hot water throughout the year – in addition to preventing c. 80 tonnes of CO2 a year from entering the atmosphere, the equivalent of 500,000 car miles.

At the end of the financial year ended 31 December 2025, we owned and managed a portfolio valued at £1.2bn and employed 27 employees across our operations, all of whom are based at our head office in London.  Our employees consist mainly of a professional team including development, investment and finance specialists.

We work with a diverse range of suppliers, contractors and service providers, making it essential to maintain high ethical standards across our business activities.

Management of modern slavery risk is shared across the compliance, development and sustainability teams, and any programmes and plans put in place to address risk need to be signed off by Executive Management.

We are a responsible employer, committed to treating our staff and suppliers with fairness, dignity, and respect and to support the protection of internationally recognised human rights.

All employees are subject to pre-employment checks which includes basic DBS and right to work checks.  All direct employees receive an offer letter and an employment contract.

In addition to the HR policies listed below, we comply with all applicable UK and European employment legislation and ensure that all our employees are paid fairly and have the right to work in the UK.  We promote equal opportunities in employment and create a safe and trusted working environment for our people.  We are committed to paying a wage rate in the UK of no less than the London Living Wage.  This commitment applies not only to directly employed staff but also to our third party contracted staff.

On joining Brockton Everlast all employees are made aware of our policies and procedures including those in respect of the prevention of slavery and human trafficking.

We consider the risk of modern slavery among our direct employees to be very low, given the size and composition of our workforce.

We have a number of policies in place which promote our culture and expected behaviours, and which accord with the Act’s objectives. The policies are clearly set out in our Staff Handbook (the “Handbook”).  These include:

• Anti-bribery and corruption – preventing exploitative labour practices linked to corruption and unethical business conduct;
• Diversity, equal opportunities and inclusion – promoting fair treatment and equal opportunities for all employees and contractors;
• Whistleblowing – providing a confidential channel for employees to report any unethical practices, including concerns about modern slavery;
• Anti-harassment and bullying – creating a safe, respectful and inclusive environment for all individuals;
• Grievance procedures – ensuring fair treatment and maintaining a positive work environment;
• Sustainability – outlining our approach to ethical sourcing, responsible procurement and social impact;
• Health and safety – ensuring the safety and well-being of all workers involved in our business operations;

These policies are currently being reviewed and going forward will be reviewed and updated annually.  They are accessible to all employees on our internal network.

We value our supplier partners and the contribution they make in delivering our business objectives.  We are committed to developing long-term mutually beneficial partnerships with suppliers whose values align with our own.

Our supply chain can broadly be categorised as follows:

• Service Partners who provide essential property management services to our occupiers including cleaning and maintenance, security and front of house and waste management.
• Professional consultants including architects, engineers, lawyers, auditors, valuers, agents and other design professionals who help us in acquiring, designing, valuing and financing our properties.
  
• Main contractors who provide materials and construction workers via a prime contractor model. Their work includes the construction of new developments and refurbishment of existing assets. We work closely with these prime contractors to ensure that our standards are maintained throughout their own supply chains.  We currently have limited suppliers in this category as we only have one development project underway.

We recognise that outsourcing and using third party labour suppliers brings with it certain risks and responsibilities.  We ensure that our project managers, contractors, cost consultants and other nominated agents undertake pre-engagement due diligence, including anti-bribery and corruption related checks for all procurement activities. We maintain and regularly review a preferred supplier list.

We acknowledge that whilst we have visibility over our direct suppliers and know the identities of the primary subcontractors used by our main contractors and property managers, in line with most companies in the property industry, we recognise that we are less aware of the identities of suppliers further down our supply chain.

During 2026 we will be introducing a Supplier Onboarding Checklist which, among other things, will require suppliers and contractors to adhere to ethical labour practices and prohibit forced, bonded or child labour.

We employ a risk-based approach to assess where modern slavery might occur within our supply chains. Based on an internal due diligence exercise we have identified that the highest risks exist within:

• Construction supply chains – particularly in relation to sub-contracted labour
• Property management services – especially cleaning and security functions
• Material sourcing for construction and refurbishment projects

We expect our suppliers to adhere to business principles and values similar to our own and seek to manage the risk of modern slavery in procured labour.  Before entering into a contract with higher risk suppliers we ensure that they are aware of the requirements of the Act.  We generally seek to use standard JCT contract wording which requires contractors to comply with the Modern Slavery Act 2015, maintain anti-slavery policies and ensure similar compliance down their supply chains.

As part of our sustainability strategy, we aim to work with responsible supply chains, and we have set ourselves the following targets:

a) Maximise the use of building materials with responsible sourcing certification

b) Work with a construction supply chain with a policy and / or track record in championing social equity.

Taking each of the key identified risks in turn we seek to reduce risk as follows:

1. Construction supply chains and sub-contracted labour

It is our policy that all contractors we engage with for construction-related activities are required to be registered with the Considerate Constructors Scheme (CCS), a not-for-profit organisation established to encourage best practices in areas including community, environment and the workforce. By registering with the CCS, the contractors commit to providing a workplace where everyone is respected, treated fairly, encouraged and supported, health and safety of the workforce is cared for, and a high standard of welfare is provided and maintained.  CCS monitors these commitments through audits.

In addition, we request that all agencies used by contractors must be a member of the REC (Recruitment and Employment Confederation).  The REC has an important role to play in continuously improving standards within the recruitment industry, and REC members are required to uphold the Code of Practice which is built on 10 guiding principles that ensure members actively demonstrate their commitment to professional and ethical recruitment.

Contractors and principle sub-contractors are required to provide us with evidence of policies and procedures that address and ensure compliance with the Modern Slavery Act 2015.  During 2026 we will obtain such evidence from all contractors working on our developments.

2. Property management services 

We work exclusively with MAPP, a UK based property management company who have thorough modern slavery procedures including vetting all suppliers and carrying out checks to ensure compliance with the Act and ETI Base Code and to identify whether they have been convicted of offences under the Act. They also carry out quarterly reviews of their key cleaning, security, MEP, landscaping, front of house and escalator suppliers against an agreed set of KPIs which are discussed and agreed with each contractor prior to contract.

For our own premises we source cleaners from a firm that pays a minimum of the London Living Wage to their staff and are accredited Living Wage Employers with the Living Wage Foundation.

3. Procurement of materials

We have made a commitment that all new developments will be Net Zero Carbon.  We also seek industry leading certification such as BREEAM Outstanding, LEED Platinum and WELL Platinum.  These certifications incentivise responsible sourcing of construction materials, including requiring verification of the source of the materials, thereby helping to reduce the risk that its extraction and production has involved human rights violations.

Wherever possible, we aim to use suppliers with responsible sourcing credentials, such as BE 6001 and ISO 14001, as well as Environmental Product Declarations, which quantify a product’s carbon footprint.  We require all materials to be sourced from the EU and UK wherever possible, where governance structures to uphold the rule of law are considered strong.

We are continuing to assess the carbon credit market in advance of completing our first major development as these currently tend to involve countries with less stringent labour laws and weaker enforcement environment.

Our culture is maintained and communicated through a robust recruitment and induction process with all employees being aware of the high standards of behaviour expected as set out in the Handbook and our Compliance Manual.  All new starters are required to complete compulsory training within their probationary period which includes a section on modern slavery and human trafficking.

We also recognise that ongoing training is crucial to identifying and preventing modern slavery.  No formal training was undertaken in 2025 but going forward our annual mandatory staff compliance training will include a section on modern slavery and human trafficking.

We recognise that the prevention of modern slavery and human trafficking requires ongoing engagement and oversight. We continue to identify and implement measures to mitigate risk, enhance transparency within our operations and supply chain, and respond appropriately to emerging and identified risks.

We continue to assess how best to monitor the effectiveness of our approaches as we implement more rigorous processes.  During the year we instituted periodic site inspections by our project management teams.

In 2026 we commit to:

• Enhancing supplier onboarding and due diligence procedures through the implementation of a Supplier Onboarding Checklist for new suppliers;
• Publishing our Sustainability Strategy, which will highlight the importance we place on responsible business conduct.
• Obtaining evidence of our contractors and principle sub-contractors policies and procedures that address and ensure compliance with the Modern Slavery Act 2015.
• Requiring regular updates, at least quarterly, from our Tier 1 contractors on site specific modern slavery procedures.
• Expanding our annual mandatory employee training programme to cover human trafficking and modern slavery;
• Developing appropriate Key Performance Indicators to enable us to measure progress and the effectiveness of the above procedures.

This Statement was approved by the Board of Directors on 18 February 2026 and is published in accordance with Section 54 of the Modern Slavery Act 2015.

Tracy Dossett

Chief Financial Officer