Modern Slavery and Human Trafficking Statement

Rookwood Operations Ltd
Last updated: 18/06/2026

1. Our commitment

Rookwood Operations Ltd is committed to preventing modern slavery and human trafficking in all areas of our business and supply chains.

We recognise our responsibility under the Modern Slavery Act 2015 and are committed to acting ethically, with integrity and transparency in all business relationships.

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2. Our business

Rookwood Operations Ltd develops and deploys innovative environmental technologies, including solutions for nutrient recovery and water treatment across the UK.

Our operations include:

• Research and development
• Technology deployment and pilot trials
• Partnerships with utilities, agriculture, and landowners
• Engagement with suppliers and contractors

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3. Our supply chains

Our supply chain primarily includes:

• Engineering and manufacturing partners
• Materials and component suppliers
• Professional services (e.g. legal, consulting)
• Field contractors and installation partners

We recognise that supply chains can present risks and are committed to managing these responsibly.

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4. Policies and governance

To minimise the risk of modern slavery, we are committed to:

• Conducting business in accordance with ethical standards
• Complying with all applicable laws and regulations
• Avoiding engagement with organisations that fail to meet acceptable labour standards

We expect our suppliers and partners to:

• Operate in compliance with the Modern Slavery Act 2015
• Provide safe working conditions
• Treat workers with dignity and respect
• Ensure work is freely chosen and fairly compensated

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5. Due diligence and risk management

We take a proportionate, risk-based approach to managing modern slavery risks, which may include:

• Assessing suppliers based on risk factors (e.g. geography, sector, labour intensity)
• Including appropriate contractual obligations where necessary
• Working with trusted suppliers and partners
• Monitoring relationships on an ongoing basis

As we grow, we intend to formalise and strengthen supplier due diligence processes.

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6. Training and awareness

We are committed to raising awareness of modern slavery risks within our organisation.

Where appropriate, we will:

• Ensure relevant team members understand modern slavery risks
• Promote ethical decision-making in procurement and partnerships

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7. Reporting concerns

We encourage openness and will support anyone who raises concerns in good faith about suspected wrongdoing.

Any concerns regarding modern slavery or unethical conduct should be reported to:
info@rookwoodperations.co.uk

Reports will be handled confidentially and appropriately.

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8. Ongoing commitment

Rookwood Operations Ltd is committed to continuously improving its approach to identifying and addressing modern slavery risks.

As the business grows, we aim to:

• Strengthen supplier onboarding and monitoring
• Introduce formal policies and controls
• Align with evolving best practice in ESG and responsible procurement

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9. Approval

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and has been approved by the board of Rookwood Operations Ltd.

Signed: Liam Pearce
Position: CCO
Date: 18/06/2026