Modern Slavery Policy

Last Updated On 20-Jan-2026

Effective Date 20-Jan-2026

Introduction

Casamia Homes Ltd (Casamia Homes) is committed to operating responsibly and ethically, with a zero-tolerance approach to modern slavery, including forced labour, child labour, human trafficking and any form of human rights abuse. This commitment applies across our own operations and throughout our supply chain.

We recognise the importance of respecting human rights and maintaining fair labour practices. Through our sustainability and responsible business principles, we seek to uphold high standards of conduct by taking a proportionate, risk-based approach to procurement, supplier engagement and continuous improvement. Our policies and procedures are aligned with internationally recognised human rights standards, including the United Nations Universal Declaration of Human Rights and the UN Guiding Principles on Business and Human Rights.

This statement is published in accordance with section 54 of the Modern Slavery Act 2015 and outlines the steps taken by Casamia Homes during 2025 and over the next 12 months to prevent modern slavery and human trafficking within our business and supply chain.

Responsibility and Governance

Overall responsibility for this statement sits with the Board of Directors, with day-to-day oversight delegated to senior management. Managers with responsibility for procurement, construction and people management are accountable for ensuring compliance with the Act within their respective areas.

This statement will be reviewed annually and published on the Company’s website. Modern slavery risks are considered as part of our wider governance and risk management processes.

Our Business and Supply Chain

Casamia Homes is a UK-based house builder engaged in the acquisition of land, securing planning consent and delivering residential developments. Our activities are carried out entirely within the UK, namely the Midlands.

We employ a direct workforce and work with a range of approved external partners, including contractors, subcontractors and suppliers of materials and services. Our supply chain plays a critical role in the delivery of our developments and includes construction trades, professional services and material manufacturers.

Where possible, procurement is coordinated centrally to ensure appropriate oversight and consistency in supplier standards, while allowing local teams to manage relationships on site.

Policies and Due Diligence

We have a number of policies in place that support ethical business practices and help mitigate the risk of modern slavery. These include policies covering whistleblowing, ethical conduct and supplier standards.

Our recruitment practices ensure that all employees have the legal right to work in the UK and are employed freely. We do not tolerate the use of forced, bonded or involuntary labour. Where labour is supplied through agencies, we expect those agencies to meet the same standards and comply with all relevant employment legislation.

We expect our suppliers and subcontractors to operate responsibly and to comply with applicable laws and regulations. As part of our engagement with suppliers, we communicate our expectations regarding ethical labour practices and seek confirmation of compliance where appropriate.

Code of Conduct and Supplier Expectations

Suppliers and subcontractors working with Casamia Homes are expected to act with integrity and to respect human rights. We seek to work with organisations that share our values and demonstrate a commitment to ethical behaviour, safe working conditions and lawful employment practices.

Where concerns are identified, we aim to work collaboratively with suppliers to address issues and drive improvement. However, we reserve the right to take appropriate action where standards are not met.

Purchasing Practices

We are committed to responsible purchasing practices and recognise that unfair commercial pressure can increase the risk of labour exploitation. We aim to pay suppliers fairly and on time and to avoid unreasonable demands that could compromise ethical standards within the supply chain.

Modern Slavery Risk

Modern slavery can occur across a range of industries, including construction, particularly where complex supply chains, subcontracted labour or temporary work arrangements are involved. Risks may also arise where materials or services are sourced through multiple tiers of suppliers.

Casamia Homes recognises these potential risks and seeks to remain alert to indicators of modern slavery within its operations and supply chain. We promote awareness among employees, subcontractors and suppliers and encourage the reporting of any concerns, so that appropriate action can be taken where necessary.

Agency Labour and Subcontractors

All agency and temporary workers engaged on our sites must have appropriate contracts in place, must not have paid fees to obtain work and must have the legal right to work in the UK. These requirements are communicated clearly to labour providers at the outset of any engagement.

We also engage a range of subcontractors to support construction activities. We communicate our expectations regarding ethical labour practices and provide information to help them understand their responsibilities under the Modern Slavery Act.

Materials Suppliers

We seek to work with material suppliers who operate responsibly and in line with applicable laws and ethical standards. We recognise that supply chains for construction materials can involve multiple stages and, in some cases, extend beyond the UK. For this reason, we aim to maintain an appropriate level of oversight and communication with our suppliers and to promote awareness of ethical sourcing and labour practices. Where concerns are identified, we expect suppliers to cooperate in addressing them.

Whistleblowing

We encourage employees, suppliers and subcontractors to report any concerns relating to unethical or unlawful behaviour, including potential modern slavery. Concerns can be raised confidentially through management or via our whistleblowing arrangements. All reports are taken seriously and investigated appropriately.

Training and Awareness

We provide training and guidance to relevant employees to help them understand modern slavery risks and how to identify and report concerns. Awareness is also raised through site briefings and communications with suppliers and subcontractors.

Continuous Improvement

We recognise that addressing modern slavery risks is an ongoing process. Over the coming year, we will continue to review our policies, assess risks and improve our processes to strengthen our approach to ethical trading and labour standards.

Approval

This statement has been approved by Casamia Homes Board of Directors on the 20th January 2026.