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Introduction

This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 on behalf of Arcadis UK (Holdings) Limited and its UK subsidiaries (‘Arcadis UK’) for the financial year ended 31 December 2025.

This statement reflects activities, progress and improvements during 2025.

There have been no issues relating to modern slavery reported in 2025.


Arcadis’ organisational structure and supply chain

Arcadis UK is the wholly owned subsidiary of Arcadis NV which is a Dutch listed company.

Arcadis operates as a global leader in design, engineering and consultancy services. It delivers sustainable solutions across the built and natural environments and works across every phase of asset creation and management for projects all around the world. Our operations span diverse industries, & involves engaging with clients, partners and supply chains. At all times we ensure we uphold ethical practices in accordance with our core values.

Our UK workforce consists of c.5,000 people working across the country providing professional consultancy services to our clients.

Our supply chain generally consists of the following two categories:

1. Professional services organisations such as sub-consultants and contingent workers; and

2. Business operational support such as suppliers who provide goods and/or services to the business i.e. facilities management staff (cleaning, security and building maintenance), stationery suppliers, PPE providers etc


Policies in relation to slavery and human trafficking

 

Arcadis General Business Principles (AGBP)

Arcadis conducts its business in accordance with our global code of conduct, the AGBP, which reinforces our commitment to respect human rights.

Global Human Rights Policy

Arcadis confirms its commitment to following international standards as outlined in the United Nations Guiding Principles on Business and Human rights (UNGPs) and the company’s responsibility to respect human rights and to prevent, mitigate and remediate adverse human rights impacts that may be directly or indirectly caused by its activities.

The Human Rights policy addresses:

1. our own operations, comprising our offices, our employees, and our contingent workforce.

2. our direct and indirect supply chains, covering the people that work in these supply chains, as well as in the supply chains of our business partners; and

3. our projects, services, solutions, and clients (including the people) as well as in the value chain of our business partners, including those that are affected by our projects, services, solutions or clients, e.g., residents in surrounding communities.

The policy explicitly prohibits forced and child labour, worker paid recruitment fees, retention of identity documents, compulsory overtime, and any form of intimidation or restriction on freedom of movement or association.

The Human Rights policy also presents the assessment of Arcadis’ most salient human rights risks, modern slavery being one of the 9 most salient focus areas:

A diagram emphasizing community and connection.

 

Global Supplier Code of Conduct

Our suppliers are expected to commit and observe our Global Supplier Code of Conduct, which aligns with our Human Rights Policy and the internally recognised frameworks and standards referenced. This code establishes clear environmental, social and governance requirements for all suppliers and contractors. Through the Global Supplier Code of Conduct, suppliers agree to provide appropriate working conditions for supply chain workers, combat child labour, forced labour, human trafficking and discrimination.

We aim to collaborate with first-tier suppliers with whom we have a direct contractual relationship, and we expect them, via our Supplier Code of Conduct, to uphold and actively cascade the same standards within their own supply chains.

Seek Advice and Speak Up Policy Statement

This Policy sets out the available reporting channels for raising concerns about unethical practices including modern slavery. It also provides a confidential and anonymous reporting line which is available to all employees as well as to third parties.

UN Global Compact (UNGC)

Arcadis has been a member of the UN Global Compact (UNGC) since 2009 and is committed to its objectives and to the ten universal principles regarding human rights, labour standards, environmental stewardship and anti-corruption.


Due Diligence Processes

Arcadis undertakes risk based due diligence on prospective suppliers at onboarding through our internal Procurement function.

Throughout 2025 we have been reviewing our Supplier Due Diligence processes in order to advance the current system and have implemented the following:

Identifying key areas for risk-based supplier due diligence

We have identified potential modern slavery risks through our Sustainability risk matrix, our internal expertise, our ESG screening and monitoring tool, and publicly available information. This risk-based approach enables us to identify geographies and purchase categories where there is a higher risk. These insights form the basis of our risk-based supplier due diligence process, and enable a more focused assessment and management of ESG risks, including modern slavery, across our supply chain.

Pre-qualification and contracting

Before entering into a business relationship with Arcadis, relevant suppliers in high-risk countries and industries undergo a due diligence process. We have increasingly centralised this process via our prequalification questionnaire and ESG screening tool, with the aim of ensuring a consistent assessment of ESG standards, In 2025, Arcadis developed ESG contractual clauses, including modern slavery clauses, for embedding ESG considerations into our contractual agreements with suppliers and contractors. These clauses are risk-based, aligned with the high-, medium-, and low-risk levels assigned to each purchase category. We are currently in the process of embedding these clauses into our supplier contract templates.

ESG screening & monitoring tool

We use an ESG screening and monitoring tool to support us in identifying potential and actual negative impacts in our supply chain and ongoing oversight of suppliers. Through this tool, we continuously screen and monitor relevant suppliers in high-risk countries and industries to identify human rights risks, including modern slavery risks. Every day, we manually analyse the intelligence that we receive and prioritise it based on severity and likelihood. We then use this intelligence to inform internal stakeholders and the expected follow-up actions. The specific mitigation measures proposed to internal stakeholders depend on the nature of the risk and its context. Our ESG screening team applies a structured set of mitigation options which can be required or recommended as part of the follow-up process.

Stakeholder engagement

While we do not conduct systematic audits of supplier premises, in 2025 we piloted new tools to strengthen on-site risk detection. These platforms provide confidential channels for workers to report concerns, helping Arcadis identify and address potential modern slavery and labour rights issues in real time. Through these pilots, we aim to assess scalability and integrate lessons learned into our ethical supply chain management. We are in the process of identifying suitable projects.

Phased implementation of a Global KYC Centralised Screening Programme (“Know Your Client”) which has been designed to screen certain categories of new clients for defined risk areas.

We continue to review our procedures with a view to advancing and maturing our approach to Supply Chain Management.

 

People Services

We also have various people related policies protecting our people from human rights abuses including modern slavery.

Recruitment

Our Recruitment Process usually includes a two-stage interview process which is carried out virtually by the Talent Acquisition Team and relevant Project Hiring Manager. This process is designed to ensure that prospective employees share our values and behaviours, have the necessary competencies to carry out the role but also to ensure that the prospective employee has applied to work with us of their own free will. In addition to this we also undertake right to work checks, and employment is conditional on them having the legal right to work in the UK.

Contingent Workers

Arcadis UK also uses agency workers (‘Contingent Workers’) as necessary. Our Contingent Workers are primarily engaged via our preferred supplier, Morson International, which is responsible for ensuring that workers are fully vetted, screened and have the necessary rights to work in the UK. It is mandatory for all Contingent Workers to read and commit to the AGBP (and other relevant polices) at onboarding. We conduct annual spot audits with Morsons which includes right to work checks and AGBP acceptance.

Bank details

A regular audit is in place to ensure that bank details provided are in the name of the person employed.

Training

Arcadis’ annual mandatory training includes a module on our code of conduct, the AGBP, which covers integrity and compliance. AGBP training compliance is formally monitored and is a key reporting metric. This has been completed by 100% of employees in the UK in 2025.

In addition, Suppliers are provided access to an online training module to facilitate their understanding of the Supplier Code of Conduct.

An internal Modern slavery online training was developed in 2023 and has been completed by 95.60% employees in the UK in 2025. An updated version is under preparation in 2025 and will be deployed in 2026. The learning objectives are as follows:

  • Explain what modern slavery is and why it matters
  • Recognise three prevalent forms of modern slavery:
    • Forced labour
    • Human trafficking
    • Slavery and slavery-like practices
  • Examine ways to identify and address modern slavery risks in Arcadis' operations

It contains a series of definitions, videos, knowledge-checks, case studies, exercises and practical resources, both internal and external, to better identify, prevent and mitigate modern slavery risks.

Arcadis is also reviewing the current training programme offered to all staff.


Risk Assessment and Management

As a professional services business, the risk of slavery and human trafficking occurring within Arcadis UK’s own operations is deemed low. However, we acknowledge that our supply chain, particularly those suppliers’ providing goods and services to the business, are likely to present a higher risk. To mitigate those risks, during 2025 we have been working towards developing additional checks, screening questions / due diligence and audits.

Arcadis has recently partnered with the Supply Chain Sustainability School providing all employees with access to a range of valuable resources and opportunities for upskilling our workforce on critical sustainability topics including modern slavery.

 

Approved by the Board of Directors and signed by
Simon Bimpson on behalf of the directors of Arcadis UK (Holdings) Limited

Simon Bimpson, Statutory Director

February 2026

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