Modern Slavery Statement

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement of RLS TopCo Ltd and its subsidiary businesses operating under the Recycling Lives Services Group for the financial year ending February 2027.

This statement outlines the steps that Recycling Lives Services has taken and continues to take to ensure that modern slavery and human trafficking do not occur within our business or supply chains. Recycling Lives Services operates a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls to safeguard against any form of modern slavery taking place within our organisation or supply chain.

Structure, business and supply chains

Recycling Lives Services is a UK-based commercial organisation operating within the recycling and waste management sector.

The organisation employs approximately 150 employees across a number of operational and administrative locations throughout the United Kingdom. Our head office is based at:

RLS Centre
1a Essex Street
Preston
PR1 1QE

Our business provides waste and resource management solutions for a wide range of sectors, alongside compliance services relating to Waste Electrical and Electronic Equipment (WEEE), batteries and packaging regulations.

Recycling Lives Services operates alongside Recycling Lives Charity UK, a social welfare charity delivering programmes including offender rehabilitation, employment support, training, accommodation for homeless adults and food redistribution.

Given the nature of our sector, we recognise that risks relating to modern slavery may exist within certain areas of our operations and supply chains, particularly within:

• supply chain procurement
• contractor and logistics services
• agency labour
• recycling and waste processing supply chains

We are committed to identifying and mitigating these risks.

Our policies

Recycling Lives Services operates a number of policies designed to ensure we conduct business in an ethical, transparent and responsible manner.

These include:

• Recruitment Policy
• Whistleblowing Policy
• Equality, Diversity and Inclusion Policy
• Code of Conduct
• Dignity at Work Policy (including anti-bullying and harassment)
• Procurement Policy
• Health and Safety Policy

These policies support our commitment to preventing modern slavery and ensuring ethical conduct across our organisation.

All policies are available to employees via internal systems or by contacting the HR department.

Due diligence process

Recycling Lives Services operates a supplier approval process and maintains a preferred supplier list.

Prior to engaging with new suppliers, we undertake appropriate due diligence checks. These include reviewing supplier practices and ensuring that suppliers demonstrate appropriate standards relating to ethical working practices.

As part of our contractual arrangements, we require suppliers to confirm that:

• they have taken steps to prevent modern slavery within their own organisation;
• they hold their own suppliers accountable for modern slavery risks;
• they will provide a copy of their Modern Slavery Statement where applicable.

We reserve the right to terminate business relationships where evidence of modern slavery or human trafficking is identified.

Risk Assessment and Management

Preventing, detecting and reporting modern slavery is the responsibility of all employees across Recycling Lives Services.

Heads of department and senior managers are responsible for ensuring that appropriate controls are implemented within their areas of responsibility.

This includes ensuring that:

• relevant legislation and regulatory guidance is monitored
• appropriate policies and procedures remain in place
• risks relating to labour exploitation are identified and mitigated
• internal controls are reviewed periodically

We also encourage a culture of openness and transparency where employees feel able to raise concerns without fear of retaliation.

Any employee who raises a concern in good faith will be supported and protected from detrimental treatment.

Key performance Indicators

We monitor the effectiveness of our approach to tackling modern slavery through a number of measures, including:

• reviewing relevant policies and procedures on a regular basis
• providing awareness training to employees and managers
• reviewing our grievance and whistleblowing procedures
• monitoring supplier relationships and compliance requirements
• reviewing any concerns raised through internal reporting channels
• reviewing reports or intelligence received from regulators or law enforcement agencies

We also continue to review employee wellbeing initiatives and support mechanisms available to staff, including access to external counselling services and support organisations.

Training

To ensure that employees understand the risks of modern slavery and human trafficking, Recycling Lives Services provides training to relevant staff, including managers and supervisors. This training helps employees recognise potential indicators of modern slavery and understand how to report concerns appropriately.

Approval for this statement

This modern slavery and human trafficking statement was approved by the RLS TopCo Board of Directors on 01/03/2026.