Modern Slavery Statement

Introduction

We are fully committed to preventing modern slavery and human trafficking in all forms within our organisation and supply chains. Although our turnover is below the £36 million statutory threshold, we voluntarily adopt the principles of the Modern Slavery Act 2015 as part of our wider commitment to ethical business practices, transparency, and corporate responsibility.

a. Organisation Structure, Business, and Supply Chains

We are a UK-based security and resilience consultancy providing advisory, training, and exercising services. Our operations are primarily UK-focused, with occasional international activity in support of government or partner organisations.

• Our business model is primarily service-based, with limited physical supply chains.

• Where we do use suppliers (e.g., IT systems, office services, travel, subcontracted specialist advisors), we seek to ensure that they operate to recognised ethical and legal standards.

b. Policies in Relation to Slavery and Human Trafficking

We maintain a zero-tolerance approach to modern slavery and human trafficking. This commitment is underpinned by our Ethical Procurement and Anti-Slavery Policy, which ensures:

• All employees, contractors, and suppliers are aware of our stance on modern slavery.

• Clear expectations are set for suppliers and subcontractors, requiring them to adhere to equivalent standards.

• Escalation routes exist for reporting concerns or potential breaches.

c. Due Diligence Processes

We apply proportionate due diligence across all suppliers and subcontractors:

• Pre-engagement checks on business practices, reputation, and compliance with legislation.

• Requirement for suppliers to confirm their own adherence to the Modern Slavery Act (where applicable).

• Ongoing monitoring through contract reviews and supplier audits, where relevant.

• Clauses in contracts reserving the right to terminate if modern slavery risks are identified or not addressed.

d. Risk Assessment and Management

Given our size and business model, the risk of modern slavery in our direct operations is low. However, we recognise potential risks in areas such as:

• Subcontracted services (e.g., specialist consultants, training providers).

• Procurement of goods and services (e.g., IT equipment, travel providers, office supplies).

Steps we take to mitigate these risks include:

• Partnering with reputable UK-based suppliers.

• Ensuring subcontractors are vetted for ethical and legal compliance.

• Avoiding suppliers with opaque or high-risk supply chains.O’Gara Security Consultancy.

e. Effectiveness and Performance Measurement

We measure the effectiveness of our anti-slavery approach through:

• Annual reviews of supplier relationships and associated risks.

• Contract monitoring to ensure compliance with ethical standards.

• Zero reported incidents of modern slavery or human trafficking within our operations and supply chains to date.

• Regular review of policies to reflect evolving best practice and legislation.

f. Training and Capacity Building

We ensure all employees and associates are aware of the risks of modern slavery and how to identify them. Our approach includes:

• Awareness training during induction, including guidance on spotting warning signs of modern slavery and trafficking.

• Refresher training as part of annual compliance updates.

• Access to external resources and best practice guidance to strengthen staff understanding.

Summary

We remain committed to acting ethically and transparently in all business dealings. We will continue to strengthen our approach to identifying, preventing, and addressing risks of modern slavery and human trafficking. By embedding these principles into our governance, supplier management, and staff training, we ensure that our operations are aligned with both the spirit and the requirements of the Modern Slavery Act 2015.

Health and Safety

Introduction

We recognise that effective health and safety (H&S) management is fundamental to safeguarding staff, clients, visitors, and contractors, while also ensuring compliance with statutory obligations. Our approach is built on robust risk management, compliance with recognised standards, and a proactive culture of safety awareness across all activities.

Policy and Governance

• We operate a formal Health and Safety Policy, reviewed annually and aligned with the Health and Safety at Work Act 1974 and associated regulations.

• Our management system is guided by the principles of ISO 45001 Occupational Health and

Safety, ensuring systematic control of risks, safe working practices, and continuous improvement.

• Responsibility for H&S lies at board level, ensuring clear accountability, supported by project-level oversight from our lead consultants.

Risk Assessment and Control

• For each project, we conduct a Task-Specific Risk Assessment and develop Method Statements (RAMS) covering all foreseeable hazards.

• Risks relevant to this Agreement may include:

o Work within public-access buildings (e.g., trip hazards, fire safety, crowd safety).

o Design and construction-related activity (e.g., contractor coordination, safe site access).

o Travel to/from sites (e.g., lone working, transport safety).

• Control measures are proportionate, following the hierarchy of control, with particular emphasis on

eliminating or reducing risks at source.

Competence and Training

• All team members are trained in core H&S requirements, including fire safety, manual handling, lone working, and emergency procedures.

• Our consultants are experienced in operating within high-risk and complex environments, including MOD facilities, policing operations, and public venues.

• Where contractors or sub-contractors are engaged, we require evidence of H&S competence and ensure alignment with our own standards through induction and ongoing oversight.

Contractor and Sub-Contractor Management

• Contractors are vetted prior to engagement, with checks on qualifications, insurance, and H&S track record.

• All contractors are required to submit RAMS for approval before commencing work.

• Our consultants maintain oversight during delivery, ensuring adherence to agreed control measures and safe systems of work.

Incident Management and Continuous Improvement

• All incidents, near-misses, or hazards are reported, investigated, and reviewed promptly, with corrective actions implemented and lessons learned shared across the team.

• Regular reviews ensure that policies, procedures, and risk assessments remain current and aligned with best practice.

• We foster a “safety-first culture”, empowering all staff and contractors to stop work if unsafe conditions are identified.

Summary

Our arrangements for managing health and safety are robust, proportionate, and embedded into every aspect of delivery. Through strong governance, thorough risk assessment, competent staff, and effective contractor oversight, we ensure risks are controlled and SMG can be confident in the safe delivery of all aspects of this Agreement.