Modern Slavery and Human Trafficking Policy

Year End 2025

Year End 2024

MODERN SLAVERY, HUMAN TRAFFICKING & CHILD EXPLOITATION STATEMENT

(Financial Year End 30-November-2025 (the “reporting period”)

Introduction

This statement is made pursuant to the UK Modern Slavery Act 2015, the California Transparency in Supply Chains Act 2010, the Australia Modern Slavery Act 2018, and the Canada Fighting Against Forced Labour and Child Labour in Supply Chains Act.
It outlines the steps taken by Megger Group Limited and its group companies (the “Group”) during the financial year ended 30-November-2025 to identify and address risks of modern slavery, including forced labour and child labour, in its operations and supply chains.

The Group is committed to conducting business in a lawful and responsible manner and expects its employees and suppliers to adhere to applicable labour and human rights standards. 

Organisation Structure and Operations

The Group is a global manufacturer in the electrical test and measurement sector. It designs, manufactures and supplies equipment used in the testing and maintenance of electrical power systems.
The Group operates across multiple jurisdictions, including the United Kingdom, Europe and the United States, and employs approximately 2050 employees worldwide.

Supply Chains

The Group’s supply chains include suppliers of components, materials and services necessary for manufacturing and business operations. These include electronic components, engineered parts, and indirect goods and services.
Suppliers are primarily located in the United Kingdom, Europe and North America, with some sourcing from other international markets.
The Group recognises that certain sectors and geographies may present a higher risk of modern slavery. These risks may include both forced labour and child labour, which can arise in different contexts and may require different approaches to identification and management.

Policies and Governance 

The Group maintains a framework of policies relevant to modern slavery and human trafficking, including:
•    Business Partner Code of Conduct
•    Anti-Bribery and Corruption Policy
•    Whistleblowing (Speak-Up) Policy
•    Procurement and supplier onboarding procedures
The Business Partner Code of Conduct sets out expectations that suppliers:
•    comply with applicable laws and labour standards;
•    do not engage in forced labour, human trafficking or child labour; and
•    maintain appropriate working conditions.
Suppliers are expected to apply equivalent standards within their own supply chains where relevant.

Risk Assessment and Due Diligence

The Group applies a risk-based approach to managing modern slavery risks, including consideration of both forced labour and child labour risks where relevant.
This may include:
•    supplier due diligence during onboarding; 
•    contractual provisions requiring compliance with applicable laws; 
•    periodic review of supplier relationships; and 
•    consideration of geographic and sector risk factors. 
Where higher-risk factors are identified, additional information may be requested from suppliers or further review undertaken.

Actions Taken During the Reporting Period

During the reporting period, the Group has:
•    conducted due diligence on new suppliers as part of onboarding processes; 
•    carried out periodic reviews of selected suppliers based on risk factors; 
•    incorporated contractual provisions relating to labour standards, including requirements addressing forced labour and child labour; 
•    maintained internal reporting channels for raising concerns; and 
•    provided training or guidance to relevant employees involved in procurement and supply chain activities. 
No substantiated instances of forced labour or child labour were identified through the Group’s due diligence processes during the reporting period.
   

Accountability and Reporting

The Group provides channels through which employees and third parties can raise concerns, including through management and confidential whistleblowing mechanisms.
Reports are reviewed and, where appropriate, investigated in accordance with internal procedures. Appropriate action may be taken where issues are identified.

Remediation

Where issues relating to forced labour or child labour are identified, the Group may engage with relevant suppliers to understand the circumstances and determine appropriate next steps. This may include requesting corrective actions or, where necessary, reconsidering the business relationship.

Training and Awareness

The Group provides training and guidance to relevant employees to support awareness of modern slavery risks, including indicators of both forced labour and child labour and how to report potential concerns.

Effectiveness

The Group monitors the implementation of its approach through internal review processes, which may include:
•    tracking supplier due diligence activities; 
•    monitoring reported concerns; and 
•    reviewing policy and process updates. 
The Group intends to continue to develop its approach over time.
 

California Transparency in Supply Chains Act Disclosures

In accordance with the California Transparency in Supply Chains Act, the Group discloses the following:
•    Verification: The Group conducts supplier due diligence through onboarding and periodic review processes.  
•    Audits: The Group may assess suppliers where appropriate based on risk.  
•    Certification: Suppliers are required, through contractual commitments, to comply with applicable labour laws and standards relating to forced labour and child labour. 
•    Internal accountability: The Group maintains internal policies and procedures addressing compliance. 
•    Training: Relevant employees may receive training on modern slavery risks. 

Consultation and Approval

The preparation of this statement has involved consultation with relevant entities within the Group. This includes engagement with regional and functional stakeholders responsible for procurement, supply chain management, legal and compliance matters to ensure that the statement reflects the activities and risks across the Group’s operations. 
This statement has been approved by the Board of Directors of Megger Group Limited and signed on its behalf.

Signed:
Dr Andrew Dodds, Chief Strategy, Marketing & Technology Officer
Financial Year End 30-November-2025
 

The Modern Slavery Act 2015 mandates that Megger Group provides a slavery and human trafficking statement to demonstrate and ensure compliance to the Act. 

Megger Group is committed to operating all aspects of its supply chain to ethical, environmental, social and safe business best practice.  As such Megger requires all vendors supplying the company to operate to the same high standards, noting that vendors shall operate within the rules, laws and regulations applicable to the country of origin. The supply chain code of conduct used and operated by Megger Group has been developed to detail the expectations from all vendors.  This is our minimum standard of practice expected, which includes appropriate due diligence to address the Modern Slavery Act 2015, implementing effective systems and controls to prevent and detect modern slavery.  All vendors must be capable of demonstrating their procedures for compliance upon request and during vendor audits which are regularly implemented in high risk countries. 

Megger reviews its supply chains and operations on a continuous and ongoing basis to check compliance with the policy, ensuring the policy is implemented effectively. 

Megger is committed to continuous improvement and includes training in Modern Slavery for key employees. Training actions are a key performance indicator for the Group and reviewed by the Group Board as part of its risk management programme. 

This policy is issued and owned by, the Megger Group Board. No deviations may be made from it without written Board approval. 

Dr Andrew Dodds 

August 2024