1. INTRODUCTION

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This statement sets out Rontec Roadside Retail Ltd and its subsidiary Companies (the Group) actions to understand all potential modern slavery risks related to the companies and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st October 2025 to 30th September 2026.

As part of the forecourt retail industry the company recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The Group is absolutely committed to preventing slavery and human trafficking in its corporate activities, in its supply chains.

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2. OUR BUSINESS

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The principal business of the Group is the ownership and operation of 267 forecourt service stations. This is carried out by the 110 employees of Rontec and supplemented by a business model of contracting with third parties (known as Commission Operators) acting as our agent and providing services in relation to the day-to-day operation of our forecourts.

The main business activities include:

• Fuel sales

• Cash wash and valet facilities

• Retail shop sales

• Fast food franchise operations

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2.1 Countries of operation and supply

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The company currently operates in the following countries:

• England

• Wales

The Group regularly reviews its countries of operation to assess whether or not particular activities or countries are high risk in relation to slavery or human trafficking.

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3. RESPONSIBILITY

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Responsibility for the company’s anti-slavery initiatives is as follows:

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3.1 Policies

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The Group operates several internal policies and procedures to provide guidance to ensure we conduct our business in a legally compliant and ethical manner. All policies are reviewed and approved by the company’s Managing Director. All policies are reviewed regularly and amended in accordance with any new legislative requirements or changes within the business.

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3.2 Risk Assessments

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The Board is responsible for reviewing the risk of our commercial activities to understand if there are any potential risks where Modern Slavery could occur.

Having risk-assessed our business the Board has identified that as we are not involved in activities where occurrences of modern slavery have been identified, we and our supply chain are both at low risk of having modern slavery occur.

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We operate with a preferred supplier list and operate with confidence that all our suppliers are aware of the Modern Slavery Act 2015. We conduct regular reviews of our supply partners to ensure they have published their own Modern Slavery statement.

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We believe that the highest risk to our business is within the operation of our service stations, where direct labour is engaged via a third-party employer (known as the Commission Operator). In this respect we have little direct control over the employment practices and activities of the independent retailer at the forecourt. We have implemented a Commission Operator Agreement that strongly encourages ethical employment activities and gives us the ability to terminate the commercial arrangement if breaches occur. We provide our Commission Operator with training to be able to understand and comply with their responsibilities as outline within this commercial arrangement to reduce the risk of non-compliance.

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We have identified that there is a significant minority of Non-EU Nationals within the working population within the retail sector, this is not specifically limited to our business but an industry wide trend so there is a potential opportunity for human trafficking and forced labour activities.

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3.3 Investigation & Due Diligence

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To minimise the risk imposed through our supplier chain, we regularly check our existing suppliers’ compliance with the publication of a modern slavery statement and if a supplier is not required to publish a statement, we request confirmation that they are not aware of any acts of modern slavery or human trafficking within their supplier chain. If a breach is discovered this is immediately raised to the Managing Director, and the contractual arrangement is immediately reviewed.

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To ensure compliance with the numerous legislative requirements linked to employee’s right to work in the UK, we carry out regular screening of our employees both during the recruitment process and periodically thereafter. If there are any suspected instances of Slavery and Human Trafficking, this would be immediately investigated by the Head of HR and findings provided to the Managing Director so appropriate action can be taken.

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Rontec carries out a detailed check for all new Commission Operators through a third-party reference checking agency that includes right to work status, residency status and criminal record information. Regular checks are carried out to ensure Commission Operators are complying with their contractual obligations as stated within the commercial agreement with Rontec. Any non-compliance with legislation e.g. minimum wage, immigration, discrimination, would be immediately investigated and reported to the Managing Director and authorities by the Head of HR.

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3.4 Training

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The Group provides on-line training to all its employees to provide an awareness of the Modern Slavery Act, and an awareness of the key risks to the company, their personal responsibilities and how to report any concerns including but not limited to the whistleblowing policy. The training forms part of the induction process and is refreshed annually.

As well as training staff, the company has raised awareness of modern slavery issues to its third-party Commission Operators and their workers through providing a mandatory modern slavery module again highlighting how to raise concerns. This is further supported through regular information bulletins highlighting important changes in ‘right to work’ obligations as well as other factors that would impact their ability to fulfil their contractual obligations such as national minimum wages rate changes.

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4. RELEVANT POLICIES & STANDARD OPERATING PROCEDURES (SOP)

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The Group operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

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• Anti-slavery Policy – The policy sets out the Group’s stance on modern slavery and explains how employees can identify and raise concerns.

• Whistleblowing Policy – The Group encourages all its employees to report any concerns related to the direct activities, or the supply chains of, the company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The company’s whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.

•  Employee Code of Conduct – The Group’s code makes clear to employees the actions and behaviour expected of them when representing the company. The company strives to maintain the highest standards of employee conduct.

• Supplier Code of Conduct & Business Ethics – The Group’s code establishes clear expectations regarding the ethical conduct and professional behaviour required of all suppliers work for or acting on its behalf. The company is dedicated to promoting and maintaining exemplary standards across all supplier relationships.

• Recruitment Procedure -We operate a robust recruitment process that includes eligibility to work in the UK checks, proof of residency and references for all new employees. The Group uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

• Commission Operator – Eligibility to Work in the UK screening – We conduct pre-contract screening as part of the first stage in the application process for all interested parties wanting to take on the operation of one of our Forecourts. This includes eligibility to work in the UK documentation check, proof of address and completion of a third-party criminal and credit check. If any concerns are highlighted during this process, the application is terminated. Periodically checks are carried out to ensure all Commission Operators remain eligible to work in the UK. If there are any changes to their eligibility, their Commission Operator Agreement is at risk of termination.

• Audits – Specific authorised Rontec Employees conduct periodical checks to ensure that employment practices of our Commission Operators are in line with the requirements of the Immigration Act 2016.

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5. PERFORMANCE INDICATORS

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The Group considers that there are two reasonable indicators that slavery and or human trafficking is not taking place within our business if:

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• we receive no reports from either law enforcement agencies, employees, Commission Operators, their workers, or the public to indicate that slavery and or human trafficking practices have been identified in relation to our business, our trading partners, or suppliers.

• That none of our third-party Commission Operators appear on the Sanction List.

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This statement is reviewed on a regular basis to ensure that a process of continued improvement is applied.

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Board Approval of Statement

This statement was approved by the Board:

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Giles Taylor

Managing Director