Modern Slavery And Human Trafficking Statement

Introduction

This statement is made in accordance with the Modern Slavery Act 2015 and constitutes Thirdway Interior’s modern slavery statement for the financial year ending 31st December 2024.

The Thirdway Group Limited (referred to as Thirdway Group herein), incorporates organisations that make up the Thirdway Group of companies. These organisations are listed at the end of this statement.

Thirdway Group is known for commercial fit-out, architecture, workplace consultancy, furniture, property technology and experiential marketing. Harnessing the power of these mixed disciplines allows us to deliver end-to-end solutions to give our Clients the outcome they need.

We have implemented policies and procedures to ensure fair and ethical treatment, these include:

• Equal Opportunities
• Code of Conduct
• Health and Safety
• Whistleblowing
• Anti-Bribery

Our Supply Chain

Our supply chain is split into the following categories:

• Sub-contractors – providing labour and materials
• Suppliers (resources) – providing direct employees and indirect labour
• Suppliers (materials) – providing materials

This supply chain is predominantly made up of organisations utilised in our construction delivery area. We directly contract sub-contractor organisations to complete work on our behalf and suppliers to provide materials or labour.

The Thirdway Group due diligence process for our supply chain incorporates a review of the controls undertaken by the supplier. All organisations that the company deals with are required to confirm that both they and their supply chain are not knowingly involved in slavery and human trafficking. Such a
declaration is required by all companies, to be added to the company’s preferred supplier list.

Risk

Where we have most control, in respect of modern slavery and human trafficking, is in recruitment of direct employees. We have procedures in place to ensure that recruitment is completed in line with regulatory requirements and our people have access to rights and appropriate conditions. We view this
area as low risk.

The highest risk to Thirdway Group is through:

1. Our temporary staff who are recruited via recruitment agencies
In 2024 we reduced the number of recruitment agencies we utilise to make the process more manageable. This was part of our approach to continually improving the recruitment process and reducing the risk to modern slavery.

In 2025 we will start auditing our recruitment agencies across a range of topics, including; modern slavery, business ethics, discrimination and bullying, recruitment practice, health and safety, payroll and competence. We will continue this process periodically as part of a continuous improvement process and feedback will be provided to the recruitment agencies to assist them in improving their systems and processes.

2. Our sub-contractor organisations whose workforce complete work on our construction sites

As already stated, in 2025 we will also start auditing our sub-contractors across a range of topics, including; modern slavery, business ethics, discrimination and bullying, recruitment practice, health and safety, payroll and competence. We will continue this process periodically as part of a continuous improvement process and feedback will be provided to the recruitment agencies to assist them in improving their systems and processes.

Training

In 2025 we will be introducing training for modern slavery which will be mandated for specific roles. This will include information on methods used to exploit victims, spotting the signs of modern slavery and the actions to take if persons believe someone is at risk.

We recognise that we can make further progress and are committed to doing this and making progress on tackling the risk of modern slavery in our supply chain.

Thirdway Group’s subsidiary companies covered by this policy:

Thirdway Interiors Ltd
Tribe Furniture Ltd
Thirdway Architecture Ltd
DThree Commercial Ltd
Thirdway Pulse Ltd

Signed for and on behalf of Thirdway Group Ltd

Rob Goulder
Chief Operating Officer