Modern Slavery Statement

INTRODUCTION

At NMBS, we are committed to tackling the fundamentally unacceptable practice of modern slavery and human trafficking and we will not tolerate the use of any form of modern slavery or child labour across our business and value chain. Due to NMBS’ unique role in facilitating payments between members and suppliers, we are aware that NMBS has significant leverage to influence suppliers in taking action to identify, prevent, and mitigate potential modern slavery and human trafficking, and to provide remedy where cases occur. This role is in line with that of the UN Guiding Principles on Business and Human Rights, which specifically outlines the responsibility of organisations to use their leverage to tackle human rights impacts.

We aim to encourage other organisations within our membership community and the wider merchanting industry to fully engage, to share what we know and have found to be effective, to offer our collateral at no cost to others, to share our challenges, to be open to learning, to lead and support innovative approaches and to identify risks. We also want to lead the way and speak out when instances of modern slavery are found.

STRUCTURE AND BUSINESS MODEL

NMBS is a co-operative owned by its members and we currently have over 1,400 members, with branches across the UK covering the full range of Independent Builders, Plumbing & Heating, Hardware, Tool and Timber Merchants.

As a co-operative, our values and principles drive us to work ethically and protect people.

During 2025, we appointed Forvis Mazars to undertake a thorough review of NMBS’s 532 suppliers for adherence to UK Modern Slavery reporting requirements. The review identified 41 of suppliers (representing 7.71% of the suppliers who trade with NMBS members through our platform) did not have an in date modern slavery statement released within 6 months of their latest annual accounts. Our trading team engaged with non-compliant suppliers to remind them of the need to ensure compliance with national law and modern slavery reporting to continue to trade via NMBS.

A Deep Dive Risk Assessment was conducted via an overarching Construction Sector Risk Review in 2023, with specific focus placed on geographies with known prevalence of modern slavery. Due to a lack of transparency around supplier sourcing locations, it was not possible to draw a direct connection to NMBS suppliers and products. However, certain suppliers who trade with NMBS members through our platform explicitly state operations within the following high-risk locations or commodity types; Vietnam, Gulf States / Middle East, Granite & Stone, and Timber. It is highly likely that additional suppliers have operations within broader construction sector high-risk areas

e.g. Asia Pacific, China, India, Copper, Tantalum, Tungsten, Tin, and the transportation of products.

POLICIES IN RELATION TO MODERN SLAVERY AND HUMAN TRAFFICKING

We have adopted a Modern Slavery and Anti-Trafficking Policy which prohibits the use of forced labour and commits NMBS to raise awareness of modern slavery and human trafficking across its members and suppliers. The policy is aligned to the ILO Conventions on Forced and Child Labour and the ETI Base Code, an international recognised set of labour standards based on the ILO conventions.

RISK ASSESSMENT

Two risk assessments have been undertaken in respect of NMBS’ suppliers, High Level and Deep Dive.

The High-Level Risk Assessment involved a thorough review of all NMBS suppliers for adherence to UK Modern Slavery reporting requirements, as reported above.

Building on a deep dive risk assessment conducted in 2023, we plan to develop internal processes to enable NMBS to identify high risk supply chains.

DUE DILIGENCE

NMBS has developed and adopted its Anti-Slavery and Human Trafficking policy. The terms and conditions between NMBS and suppliers require all suppliers to comply with all applicable anti-slavery and human trafficking laws and regulations and to have their own policies and procedures in place to ensure compliance.

The review NMBS undertakes of prospective suppliers includes a risk assessment which determines the compliance with national law and modern slavery reporting of the prospect.

TRAINING

Training and collaboration play a major role in helping to prevent slavery and human rights abuses. We are committed to work closely with our colleagues and suppliers to help build their capacity to identify, manage and deal with risks of modern slavery.

We have introduced compulsory training for all NMBS employees on modern slavery. This training is conducted annually.

REPORTING

Employees can report any suspicions of slavery either through the Company’s Whistleblowing policy or externally to the Modern Slavery Helpline at https://www.modernslaveryhelpline.org/ or 0800 0121 700.

STATEMENT OF COMMITMENT

This statement and the actions contained herein have been approved by the Executive Board of Directors and by Kevin Williams, Chief Executive Officer, for the financial year ending 31 December 2025. This statement will be reviewed and updated every year.