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Introduction

This statement is made voluntarily by Blackfeather Procurement Ltd ("Blackfeather") and sets out the steps we take to ensure that modern slavery and human trafficking do not take place within our business or our supply chains.

While Blackfeather does not currently meet the statutory turnover threshold (£36 million) requiring a mandatory statement under section 54(1) of the Modern Slavery Act 2015, we are publishing this voluntary statement to demonstrate our absolute commitment to ethical trading principles and robust supply chain governance.

Our Business and Structure

Blackfeather Procurement operates as a specialist supply chain partner and procurement framework for the UK housebuilding sector. We aggregate the material volume of regional and SME property developers to secure improved pricing and service levels. Because we sit between national material manufacturers and regional developers, we recognize our unique responsibility to act as a gatekeeper for ethical procurement.

Our Supply Chains

Our primary supply chains involve onboarding and partnering with UK and global manufacturers, distributors, and merchants of construction materials. The construction sector and its associated material supply chains are widely recognized as carrying a higher risk of modern slavery. Consequently, Blackfeather operates a zero-tolerance approach to modern slavery, forced labor, and human trafficking.

Our Policies and Due Diligence

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains. As part of our "Supply Chain as a Service" offering, we actively de-risk the build process for our SME developer clients by conducting due diligence on the suppliers we admit to the Blackfeather Framework.

Our vetting processes include:

• Supplier Assessment: Evaluating the financial stability, accreditations, and ethical trading policies of our supply chain partners before onboarding.

• Mandatory Compliance: Expecting all manufacturers, distributors, contractors and service providers operating on our framework to have their own robust Modern Slavery statements and policies in place, commensurate with their size and statutory obligations.

• Ongoing Monitoring: Maintaining open dialogue with our supplier network regarding their sourcing ethics and workforce conditions.

Risk Assessment and Management

We continually assess the risk of modern slavery within our operations. If we identify any potential risk or breach of the Modern Slavery Act 2015 by a supplier on our framework, we will immediately review our commercial relationship with that entity, which may result in their removal from the Blackfeather Framework.

Approval

This voluntary statement has been approved by the Director of Blackfeather Procurement Ltd for the financial year ending 31 March 2027. We are committed to reviewing and updating this statement annually to reflect our ongoing efforts.

Oliver Philips Director, Blackfeather Procurement Ltd

Date: 12 May 2026