Modern Slavery and Anti-Trafficking Policy

1.1
This document constitutes Doka UK’s Modern Slavery and Human Trafficking Statement made pursuant to section 54 of the Modern Slavery Act 2015. It sets out the steps taken during the current financial year to prevent modern slavery and human trafficking in Doka’s business operations and supply chains.

1.2
This statement also operates as Doka UK’s internal Modern Slavery and Anti-Trafficking Policy, and applies to all employees, agency workers, contractors, suppliers and other business partners engaged with Doka.

1.3
Doka is committed to acting ethically and with integrity in all business relationships and to implementing effective systems and controls to ensure modern slavery does not take place in any part of its business or supply chains.

2.1
Doka is a global formwork specialist and a leader in the development, manufacture and distribution of formwork technology for use across the construction sector. Doka operates through more than 160 sales and logistics facilities in over 54 countries, providing equipment and technical support internationally.

2.2
In the UK, Doka engages employees, contractors and suppliers across construction-related activities, logistics, manufacturing support and professional services. Given the global nature of its operations and supply chains, Doka recognises that there is an inherent risk of modern slavery within parts of the construction sector and associated supply networks.

The key risks of modern slavery relevant to Doka’s operations and supply chains include:

3.1 Lack of formal contracts of employment, including the misuse of zero-hours contracts

3.2 Underpayment of employees, self-employed contractors or subcontractors, including failure to pay the National Minimum Wage

3.3 Excessive working hours and insufficient rest periods

3.4 Individuals working without the legal right to work in the country of employment

3.5 Poor physical working conditions, including health and safety risks

3.6 Bullying, discrimination or harassment

3.7 Labour-intensive activities and complex or multi-tier supply chains

Doka undertakes proportionate due diligence to mitigate the risk of modern slavery within its business and supply chains. As a minimum, Doka ensures that:

4.1 All individuals engaged by Doka have the legal right to work in the country of employment

4.2 At least the National Minimum Wage is paid

4.3 Pay reflects current market values for the sector and role

4.4 Working time regulations are complied with and excessive working hours are discouraged

4.5 Bullying, discrimination and harassment are not tolerated in any form

4.6 Working environments are safe and support the protection of health, safety and wellbeing

4.7
Doka’s contractual arrangements require suppliers and contractors to comply with applicable laws relating to modern slavery and human trafficking. Doka reserves the right to investigate concerns and take appropriate action where risks or breaches are identified.

4.8
Doka also expects its customers to conduct business ethically and to treat Doka fairly as a supplier, including in relation to payment terms and rates of pay.

5.1
Doka provides training to relevant staff to ensure awareness of modern slavery risks, indicators of exploitation and individual responsibilities under this policy. This training supports early identification of concerns and promotes ethical labour practices across the business.

6.1
All employees and workers are encouraged to raise concerns about suspected modern slavery or human trafficking, whether within Doka’s operations or its supply chains. Concerns may be reported through established management channels or via Doka’s confidential reporting and whistleblowing procedures. All reports are taken seriously and handled appropriately.

7.1 The implementation and effectiveness of this policy and statement are monitored as part of Doka’s management processes. This includes consideration of training completion, any concerns raised, and corrective actions taken. Oversight of modern slavery controls forms part of annual management review and performance evaluation.

8.1
Where an actual or potential instance of modern slavery is identified, whether internally or within the supply chain, Doka will take appropriate corrective action in line with its Control of Non-Conformity Procedure. All non-conformities are recorded, investigated and addressed in a timely manner.

This policy and statement are reviewed annually, and additionally following any significant change in business operations, supply chains, or where lessons are identified through incidents or non-compliance.

This Modern Slavery and Anti-Trafficking Policy and Statement has been approved by the Board and is signed by a Director, as required under section 54 of the Modern Slavery Act 2015.

Endorsed by the Company Directors Name & Position: Lee Davidson – Managing Director

Dated: 01/04/2026