MSA/ethics

MSA / ETHICS

This Policy Statement is made pursuant to section 54, Part 6 of the Modern Slavery Act 2015 (the Act) and constitutes px Limited’s (px) slavery and human trafficking statement for the financial year ending 31 March 2025.

px is committed to improving its practices to combat slavery and human trafficking in its business and supply chains. px aims to avoid causing or contributing to adverse human rights impacts through its own business activities and will address such impacts when they occur.

Business and Supply Chains

px group is a fully integrated infrastructure solutions business that delivers innovative solutions for our clients by focusing on three key delivery areas: (i) operations and maintenance; (ii) energy solutions; and (iii) projects, engineering and consultancy.

px delivers services across the UK, Europe and North America and contracts with businesses in the UK, EU and Worldwide for the supply of goods and services to px.

Policies

px has appropriate policies in place that underpin its commitment to ethical business conduct and all policies are subject to regular review and update. px policies include the following:

Anti-Slavery and Human Trafficking Policy - reflects px’s commitment to acting ethically and with integrity in all business relationships and to implementing and enforcing effective systems and controls to ensure slavery, human trafficking and human rights abuses are not taking place anywhere in its supply chains.
Anti-Bribery and Corruption Policy - sets out a zero-tolerance approach to bribery and corruption and details how employees can recognise and deal with bribery and corruption issues.
Whistleblowing Policy - encourages employees to report any wrongdoing including human rights violations such as slavery and human trafficking.
Employee Code of Conduct - underpins and clarifies the standards required by the Company of its employees in the provision of their services.
Procurement General Principles - ensures that px demonstrates and promotes professional and ethical behaviour with both suppliers and customers.

Due Diligence Processes

px is committed to acting ethically and with integrity in all of its business dealings and relationships. px recognises the importance of conducting appropriate due diligence on its supply chain. To identify and mitigate supply chain risk, px has in place systems to:

Identify and assess potential risk areas in its supply chains.
Mitigate the risk of slavery and human trafficking occurring in its supply chains.
Monitor potential risk areas in its supply chains.
Protect whistleblowers.

px undertakes due diligence on all new suppliers which includes health & safety and environmental standards, labour relations and employment practices. Suppliers are required to confirm that neither slavery nor human trafficking takes place within their organisation and disclose details of any investigations into their compliance with modern slavery and human trafficking or human rights legislation generally.

Ongoing monitoring of suppliers is conducted through risk assessments and audits. px has implemented IT monitoring tools to support supplier audits, enhance supply chain visibility and promote compliance with all relevant standards.

px acknowledges that contracting with companies, whether based in the UK, Europe, North America or outside those jurisdictions, potentially gives rise to the risk of slavery, human trafficking and human rights issues. As such, the level of management control required will be kept under review.

Training

All px employees are required to complete training on modern slavery which is delivered through px’s e-learning system. The module includes an assessment and has a required pass rate of 100%. The training aims to ensure a high level of understanding of the risks of modern slavery and human trafficking in px’s supply chains and business. The training also encourages employees to report any issues or suspicions of modern slavery or human rights abuses in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

Corporate Statement

px is committed to driving out acts of modern-day slavery, if discovered, from within its business and from within its supply chains. px acknowledges its responsibilities under the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation. Accordingly, px group will not:-

knowingly be involved in slavery or human trafficking in any of the services it provides;
accept any goods and/or services from suppliers that are knowingly involved in slavery or human trafficking; or
deal with any business knowingly involved in slavery or human trafficking.

This Policy Statement has been approved by the board of directors of px (in consultation and with approval by the trading companies in px group) and a new statement will be published annually.