Modern Slavery Act

Murphy has a zero-tolerance approach to Modern Slavery which is the use of forced, compulsory or trafficked labour or the holding of anyone in slavery or servitude whether they are adults or children. We are committed to acting ethically and with integrity in all our business dealings and relationships. We expect the same high standards from all our supply chain partners. We expect them to adopt the same zero tolerance approach to Modern Slavery. We expect our supply chain partners to hold their own suppliers to the same high standards.

Murphy is an international, multi-disciplined engineering and construction company. J Murphy & Sons Limited is the main trading company of the Murphy group of companies (‘the Group’). The Group has over 4,000 employees worldwide and operates in the United Kingdom, the Republic of Ireland and as part of a joint venture in Canada and the United States. The Group had a global annual revenue of more than £1 billion in 2024.The Group delivers world-class infrastructure by executing construction projects in the infrastructure sectors. The Group does not produce or sell goods but does purchase goods from its supply chain to deliver its services.

Our supply chains include in the region of 4,000 suppliers, with around 350 of these suppliers accounting for 80% of our expenditure on a regular basis. Our direct suppliers are predominantly UK or EU based and support our business in the provision of labour, plant, materials, equipment and professional services.

We are committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery Policy reflects our commitment to act ethically and with integrity in all our business relationships. We are committed to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. This is guided by one of the core values of business: Respect, Integrity and Accountability.

We take responsibility for conducting and growing our business in a safe, sustainable and responsible manner. We understand the impact our activities can have on the environment and society around us. We endeavour to ensure we eliminate or mitigate the risk of negative impacts and leave a positive legacy in the communities where we work. Our Murphy at 75 strategy sets out specific targets around Climate Action and Social Value, making sustainable decision making an integral part of the way we do business. We also have policy statements in relation to Environment, Social & Governance (ESG) and Sustainable Procurement which are made available internally and to our supply chain.

We have signed the Construction Protocol with the Gangmasters and Labour Abuse Authority (GLAA), and with other members of our industry, to support the objective of eradicating slavery and labour exploitation in the sector.

Our Anti-Slavery Policy sets out our approach to Modern Slavery and applies to everyone working directly or indirectly for, or with, us. We recognise that appropriate training on modern slavery and the use of forced, compulsory or trafficked labour will increase awareness among our people as well as mitigating the risk within the business and the supply chain.

Modern Slavery compliance is an integral part of our supplier approval and pre-qualification processes. As part of our supply chain accreditation process, we require our supply chain to comply with the Modern Slavery Act 2015. We include our Anti-Slavery Policy in our contracting processes to ensure our supply chain are aligned against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude.

We use standard industry accreditation schemes to certify our supply chain’s compliance with Modern Slavery requirements. This is carried out on an annual basis.

We recognise that the construction sector in the United Kingdom and Ireland has particular risks relating to modern slavery and is one of the sectors where the GLAA has the most referrals and cases to investigate.

We consider the following key risks relating to modern slavery for our business are:

• Supply of labour through agencies or other third parties which is subject to coercion and under the control of organised criminals.
• Engaging direct labour which is subject to coercion and under the control of organised criminals.
• The multiple tiers in our supply chain where goods which may be manufactured in jurisdictions which have greater risk of forced labour or child labour.

We have a zero-risk appetite for these risks.

We manage these risks:

• By committing our direct supply chain to complying with our Anti-Slavery Policy.
• By selecting responsible providers through a proper due diligence process and continued engagement with them on their labour resources.
• By right to work on commencement of employment and other identity checks during employment.
• By training and educating our people
• By auditing our supply chain partners’ compliance with our policies.

We adopted the following KPIs in 2024 to measure our effectiveness in assessing and managing the risk of modern slavery:  

• Undertake an external audit on our processes for eliminating and mitigating the risk of Modern Slavery in our business and supply chain.
• Complete 15 audits on Modern Slavery compliance in the supply chain
• Co-ordinate toolbox talks on all projects with Anti- Slavery Week in October 2024.

We were audited by The Slave Free Alliance on our processes for dealing with the risk of modern slavery on one of our projects. Among the key findings, the risk of modern slavery on the project was considered to be low.

We completed 15 audits on the supply chain in the United Kingdom including modern slavery compliance during the year.

We completed the toolbox talk  advising our people on the warning signs to look out for where there may be incidences of modern slavery and advising them how to report any concerns in January 2024.

We have adopted the following KPIs in 2025 to measure our effectiveness in assessing and managing the risk of modern slavery:

• Complete 20 audits, including in Ireland, on supply chain on Modern Slavery compliance.
• Conduct enhanced Modern Slavery awareness training for all members of our recruitment and resource operations teams.
• Undertake review of higher risk products from higher risk countries and implement any additional controls required.

We recognise that appropriate training on Modern Slavery will increase awareness among our people, as well as mitigating the risk within the business and the supply chain.

Our Code of Conduct forms part of our induction process for all new starters and is a compulsory training requirement for existing employees within the business. It explains what Modern Slavery is and informs our people that it is their responsibility to help prevent, detect and report incidences of Modern Slavery. It advises our people to raise concerns about incidences of Modern Slavery through management or our independent confidential helpline managed by Safecall.

We are partners of the Supply Chain Sustainability School, through which we provide specific training to our Procurement Team on the relevant legislation. Our Procurement Team also take the CIPS ethics course annually.

We have included in our toolbox briefings to our projects, a specific briefing on Modern Slavery, advising our people on the warning signs to look out for where there may be incidences of modern slavery and advising them how to report any concerns.

The business’s approach to the prevention of Modern Slavery has stakeholder buy in from the highest levels of management within our organisation. The policy has been considered and formally ratified by the Board. The Company Secretary and General Counsel is the appointed Compliance Officer.

The Compliance Officer is responsible for dealing with any concerns about compliance with the Act as well as the protections in place for anyone who brings matters of concern to our attention.

We are satisfied that we have in place systems to:

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

We have no reason for concern in relation to any current member of the supply chain and their compliance with the Modern Slavery Act.

Murphy and Surerus Pipelines Inc, operate under a joint venture agreement known as Surerus Murphy Joint Venture (SMJV) in Calgary, Alberta. These entities deliver construction projects in the pipeline and infrastructure sectors. While the entities do not currently produce or sell goods, they do distribute and import goods in Canada as part of the operations and supply chains. Occasionally, materials may be procured from suppliers who source or manufacture outside of Canada.

SMJV suppliers consist of 500+ third parties that provide materials, goods and services including contractors, subcontractors, vendors and independent consultants.

To ensure compliance throughout SMJV’s supply chain and prevent third-party exposure to forced and child labour, the Third Party Code of Conduct Standard (the ‘Standard’) sets clear expectations for all parties. This Standard applies to SMJV and any Third Parties (organisations that provide materials, goods, and/or services to SMJV, including contractors, subcontractors, vendors, and consultants).

The Standard aligns with the core procedures and ethical standards, emphasising our commitment to the highest business conduct. It outlines the requirements for ethical practices, including a zero-tolerance approach to forced labour and child labour. All suppliers must adhere to these standards, ensuring safe working conditions, fair treatment, and legal labour practices.

Third Parties are fundamentally required to take all reasonable measures to ensure they respect, uphold, and communicate this Standard across their business and within their own supply chains connected with the Third Parties’ contract(s) with SMJV.

SMJV operate within the construction sector which has been identified as a potential industry in Canada carrying high risk for forced labour and child labour. Collaborative relationships are built with Tier 1 suppliers on projects and supplier oversight is in place. The entities’ Greenhand Program is in place to ensure all new or underage workers are identified and mitigations are put in place to prevent any forced labour or child labour issues.

No remediation measures have been required to date as no issues of forced labour or child labour have been identified.

Training was conducted for all front-line leaders and key stakeholders identified to have potential exposure to high-risk activities.

Supplier audits and inspections are in place to ensure that no forced labour or child labour risks are being identified along with supplier prequalifications. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and applies to the following companies in our Group:

Drilton Limited

J.Murphy & Sons Limited

J.M Piling Co Limited

Murphy Power Networks Limited

Murphy Technical Services Limited

Murphy International Limited

Murphy Process Engineering Limited

Murphy Group Canada Limited

It constitutes our Group’s slavery and human trafficking statement for the financial year ending 31st December 2024 and outlines the steps we have taken as an organisation to assess our operations and supply chain and mitigate any risk of slavery and human trafficking.

John Murphy, Chief Executive Officer
J. Murphy & Sons Limited

June 2025