Code of Conduct

ESH GROUP CODE OF CONDUCT

Act Ethically and with Integrity Treating People with Respect and Dignity Achieving a Safe Environment for all Protecting the Environment

Message from Andy

This Code of Conduct sets out our approach to being a responsible business and one that leads the way in constructing communities.

Esh Group is a construction company that puts local communities at the heart of our activity and supports them by developing the built environment and adding social value for the economies local to them.

Whilst recognising the importance of shareholder value, Esh Group makes sure that our actions never compromise our core values.

This is because we listen to our employees, customers and stakeholders. We also recognise our responsibility to the environment and the communities where we work, while health and safety is paramount at all times at our company. Our Core Values are: Act ethically and with integrity Be open, honest and sincere, while treating with respect our employees, customers and all people with whom we come into contact.

Teamwork is at the forefront We work as a team throughout the whole of the Group. Our culture is to table problems/issues early and provide support to determine solutions.

Forward thinking, innovative, dynamic, always looking for improvement It may be challenging at Esh Group but it’s rewarding to be part of a Group that never stands still.

Brand and reputation are at the heart of the Group Our core values, delivered by our brands, are central to the Group’s reputation.

Andy Radcliffe Chief Executive

CONTENTS

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SECTION 01 - ACT ETHICALLY AND WITH INTEGRITY

01

Whistle Blowing Anti Corruption & Bribery Data Protection Ethical Sourcing

02 02 05 05

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SECTION 02 - TREATING PEOPLE WITH RESPECT & DIGNITY

06

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Equality & Diversity Slavery & Human Trafficking Bullying & Harassment

08 08 10

SECTION 03 - ACHIEVING A SAFE ENVIRONMENT FOR ALL

12

Esh Safe: Everyone Safely Home Customer Care Safeguarding Children & Vulnerable People

15 15 16

SECTION 04 - PROTECTING THE ENVIRONMENT

18

Summit 2026:

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Culture Supply Chain Carbon Emission Waste Management Environmental Protection

21 22 22 25 25

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ACT ETHICALLY AND WITH INTEGRITY

SECTION 01 Whistle Blowing Anti Corruption & Bribery Data Protection Ethical Sourcing

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Whistle Blowing At Esh Group we encourage all of our employees

However, if staff feel it is not appropriate to

to conduct activities to the highest standard

report any issues to their line manager or they

however we are aware that occasionally things

feel uncomfortable doing this, then there are

may go wrong. At any point in a staff members

alternative nominated persons within the Group

career they may experience or witness dishonest

and alternative routes for reporting such as via

or unethical behaviour, health and safety

email on eshgroup@safecall.co.uk or on the

breaches, harassment, bullying or other forms of

internet at www.safecall.co.uk. SafeCall is an

wrongdoing.

independent service which is available for use when circumstances necessitate a different

As an organisation we are committed to reducing

approach to reporting. SafeCall provides

any unethical practices in the workplace. The

employees with a confidential means of reporting

existing Esh Group Whistle Blowing Policy and

concerns.

Procedures have recently been revised and updated to ensure employees can report their

Speak Up posters are located around our offices

concerns in an effective and timely manner.

and also on every established construction site.

These posters have been designed to provide all

All employees can help the Group in the fight

the information staff need in order to lodge any

against any unethical practices by reporting any

concern.

suspicions of malpractice to their line manager.

Anti-corruption & Bribery Esh Group’s policy is to conduct all of our business

(a) Set out our responsibilities, and of those

in an honest and ethical manner. We take a zero-

working for us, in observing and upholding our

tolerance approach to bribery and corruption

position on bribery and corruption; and

and are committed to acting professionally, fairly

(b) Provide in formation and guidance to those

and with integrity in all our business dealings

working for us on how to recognise and deal with

and relationships wherever we operate and

bribery and corruption issues.

implementing and enforcing effective systems to counter bribery.

Esh Group’s zero-tolerance approach to bribery and corruption is communicated to all workers,

Esh Group will uphold all laws relevant to

third parties and business partners at the outset

countering bribery and corruption in all the

of our business relationship with them and as

jurisdictions in which we operate including

appropriate thereafter.

the Bribery Act 2010, in respect of our conduct in the UK and in the unlikely event, regarding

Changes in legislation, regulation and emerging

transactions with overseas companies or

construction sector and regional business issues

individuals.

are continually reviewed to keep both the policies and procedures up to date and relevant.

The purpose of this policy is to:

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Data Protection Esh Group is committed to the highest standards

whom we work in order to operate and carry out

of quality, probity, openness and accountability.

our functions. These may include members of

Esh Group requires all staff at all times to act

the public (including residents), current, past and

honestly and with integrity, and to safeguard the

prospective employees, clients and customers

information for which they are responsible.

and suppliers. This personal information must be handled and dealt with properly however it is

Esh Group is fully committed to full compliance with

collected, recorded and used and whether it is on

the requirements of the Data Protection Act 1998.

paper, in computer records or recorded by other

Our operations will therefore follow procedures

means.

which aim to ensure that all employees, subcontractors, consultants, partners or other agents

Esh Group regards the lawful and appropriate

of the company (collectively known as data users)

treatment of personal information as very

who have access to any personal data held by or on

important to its successful operations and

behalf of Esh Group are fully aware of and abide by their duties under the Data Protection Act 1998.

As part of our business operations we often need to collect and use information about people with

essential to maintaining confidence between our business and those with whom we work alongside.

We therefore fully endorse and adhere to the Principles of the Data Protection Act 1998.

Ethical Sourcing Esh Group is committed to operating in a

We will be open, transparent and fair in our

socially responsible manner by minimising our

communications and dealings with business

environmental impact. Every year we spend

partners and other stakeholders affected by our

many millions of pounds purchasing goods

supply chain activities.

and services to support the delivery of our construction and general business activities. We

We will fulfil the payment terms and other

pursue responsible purchasing practices that are

conditions agreed with our business partners.

attuned to our Corporate Social Responsibility

Our aim to have a large proportion of our supply

policy. The purpose of this policy is to explain

base as local necessitates prompt payment to

how we uphold our CSR policy throughout our

ensure continuity of successful relationships with

supplier management and procurement activities

our supply chain. We believe that we benefit

wherever we are able to exert influence or direct

by having this as one of the key aspects of our

control. We also promote the application of this

business culture. Through our bespoke ‘Elite’

policy throughout our supply chain partners,

system for invoicing and payment we ensure that

prevailing Standard Terms and Condition of

our supply chain are paid promptly. Esh Group

Purchase and our supplier questionnaire for any

is a signatory to the Prompt Payment Code. We

prospective new supplier.

regularly monitor all suppliers payment days and report on payment performance to the board on

We will ensure integrity in all our business

a monthly basis.

transactions.

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TREATING PEOPLE WITH RESPECT & DIGNITY

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SECTION 02 Equality & Diversity Slavery & Human Trafficking Bullying & Harassment Ethical Sourcing

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Equality & Diversity We understand the importance of having equality

We are proud to have been accredited to the CITB

for all employees here at Esh Group. We also strive

Be Fair Framework within 2016.

to be the employer of choice, provide opportunities for all, value diversity and promote inclusion. We

Our Modern Slavery Human Trafficking Statement

have an inclusive culture where every staff member

sets out the steps that Esh Group has taken, and

is treated with respect and dignity. Most importantly,

continues to take, to ensure that modern slavery

we ensure everyone has the same opportunity to

or human trafficking is not taking place within our

progress and meet their full potential.

business or supply chain.

We believe that discrimination, harassment and

All recruitment advertising and application

bullying are unacceptable and aim to provide a

forms carry our Equal Opportunities statement

working environment free from those things. We

and, our selection methods include using

have set guidelines for employees to follow if they

structured interview techniques. We are an

feel like they are victims of discrimination via a

equal opportunities employer and aim to attract

confidential outsourced whistleblowing hotline

and recruit candidates from all sections of the

telephone number.

community. Consequently our efforts have also included holding recruitment events within the local areas in which we work.

Slavery & Human Trafficking Esh Groups commitment to conduct all business

in UK, Recruitment and Selection, Equality and

activities fairly and ethically is well established.

detailed codes of conduct to ensure employees

Esh Group and Board are therefore committed to

are treat fairly, with respect, in a safe working

the objectives of the Modern Slavery Act.

environment at all times.

Through our Ethical Governance policy, the

Within Esh Groups Supplier Relationship

highest standards of integrity and accountability

Management, we have started to

are put into practice by the Board and expected to be adhered to by all company directors,

•

and the “Global Slavery Index” and how this

employees, third parties, including subcontractors and their employees.

Esh Group complies with employment laws, and provides clear policies that include Right to Work

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Raise awareness of the Modern Slavery Act forms part of their code of ethics.

•

Seek confirmation that our supply chain prohibits the use of illegal child, coerced or forced labour and any other form of human trafficking or slavery.

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Bullying & Harassment As an equal opportunities employer, Esh

•

Protect confidentiality as far as possible;

Group is committed to creating a diverse

monitor the implementation of the policy and

workforce in a working environment in which all

review it on an ongoing basis, to ensure that it

individuals show, and are shown, respect and

continues to be effective.

consideration for one another.

Harassment, bullying and victimisation are The purpose of this policy is to support the

viewed as Gross Misconduct and disciplinary

development of a working environment and

action, which could include dismissal, will be

culture in which harassment and bullying

taken if any complaint of harassment, bullying or

is know to be unacceptable, and where

victimisation is upheld.

individuals have the confidence to report harassment and bulling without fear of ridicule or reprisals.

Esh Group therefore deplores all forms of harassment and bullying, which will not be tolerated under any circumstances. (Equality & Diversity Policy) In order to ensure that the policy is adhered to, the Company undertakes to; •

Treat any complaint of harassment promptly, sensitively and thoroughly;

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ACHIEVING A SAFE ENVIRONMENT FOR ALL

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SECTION 03 Esh Safe: Everyone Safely Home Customer Care Safeguarding Children & Vulnerable People

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Everyone Safely Home Esh Group’s Everyone Safely Home campaign is

Esh Group maintains commitment to the Everyone

designed to keep people safe across our business

Safely Home campaign, administered under the

and the communities in which we operate. It’s

Esh Safe brand.

a vision of health and safety practice that has helped us dramatically reduce our Accident

As a guiding principle of the group, Everyone

Incidence Rate to well below the construction

Safely Home has helped us dramatically reduce

industry average.

our Accident Incidence Rate to well below the construction industry average.

We have a dedicated health and safety team of 11, who cover all companies within our operational

In 2017 the campaign will include measures

areas. They also write our health and safety

to adhere to the Health and Safety Executive

policy, which is reviewed annually and available

strategy “Helping Great Britain Work Well”,

to all staff. We work hard to make sure that

which includes occupational health and

our H&S policy is well known, respected and

hygiene controls.

implemented by our employees and supply chain. Customer Care

Customer Care It is our policy to provide the highest level

•

We will maintain good lines of communication

of service to our customers. We will do this

with residents by whichever appropriate

by establishing our customer’s needs and

method is necessary, e.g. by use of

meeting them.

interpreters etc.

•

Our Policy Is:

a confidential manner •

• •

To treat all of our customers fairly and with courtesy and respect

•

We will keep residents informed of progress

To communicate promptly and effectively in

•

We will carry out surveys to monitor and

To liaise with our customers to ensure that we are providing the service that they require

•

We will make and keep mutually convenient appointments with our customers

an appropriate manner •

We will treat residents’ personal information in

maintain high levels of resident satisfaction •

We will deal with any complaints promptly and in a positive manner

To ensure our staff are sufficiently resourced and trained to provide a high quality service

It is our policy to monitor customer satisfaction to ensure that expectations are exceeded and that

With Regard to Operations on Site: •

any improvements necessary are put in place.

We will ensure that all of our staff can identify themselves as employees of Esh Properties Services

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Esh Group Code of Conduct

Safeguarding Children & Vulnerable People Our policy sets out the commitment of Esh

Esh Group firmly believe that Safeguarding is

Group, its Board of Directors, Chief Executive

everyone’s responsibility and that ‘no action is

and Senior Management to the Safeguarding of

not an option’. Esh Group employees and our

vulnerable adults and children.

supply partners will inform our Site Safeguarding Contact immediately should there be a

We are committed to the development of good

suspicion that someone is being harmed or that

practice and sound procedures which enables

there is evidence of someone being harmed. All

safeguarding concerns and referrals to be

disclosures are noted, dated and signed.

handled sensitively, professionally and in ways that supports the needs of vulnerable persons.

Our HR Department keeps a full record of concerns raised and makes referrals to school,

We fully recognise the contribution we can make

college, social services and the police if

to safeguard and support children and adults

necessary.

during the course of our service delivery.

We ensure that all Management and Service Communication and proper planning is the

Delivery Teams receive Safeguarding training

key to ensuring that all persons involved in our

relevant to their role. The organisation ensures

projects are aware of risks and the identification

that all employees are kept informed about

of safeguarding issues. We consider the main

Safeguarding issues through a programme of

safeguarding risks to be;

staff information and toolbox talks as part of our

• Children or Young Persons • Elderly Residents • Mental Health Issues • Disability

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Health, Safety and Welfare Programme.

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PROTECTING THE ENVIRONMENT

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SECTION 03 Cultue Supply Chain Carbon Emissions Waste Management Environmental Protection

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Summit 2026 We know the link between the built and natural

•

environments should be a sustainable one.

management and disposal, in line with the

Summit 2026 is our response to this challenge.

The strategy covers energy use, our carbon footprint, waste management and ethical sourcing

Ensure effective and responsible waste relevant legislation and the requirements of our clients.

•

Development of a carbon management training course for our apprentices -Esh

of materials, and acts as an umbrella identity under

Carbon Coach.

which sustainability policies are promoted within Esh Group and our supply chain.

Summit 2026, Esh Group’s internal sustainability Summit 2026 is driven by the ISO 14001:2004

programme, helps us to address the needs of

and ISO 50001:2011 management systems,

our clients, provide an identity for environmental

and helps make us a sustainable company.

The 10-year strategy includes short (<1 year), medium (1-5years) and long term (5-10 years) environmental commitments. Those commitments include: •

•

sustainability and allows the Group to implement the updated version of the international environmental management standard.

The ten-year time frame will allow the Summit

Certify to the updated standard for

2026 programme to set short, medium and long-

Environmental Management Systems (ISO

term policy commitments and update objectives

14001:2015).

annually, demonstrating continual improvement.

Protect the environment by identifying and mitigating environmental impacts during the lifecycle of construction projects.

Objectives have been set to minimise the Group’s exposure to risks and maximise the benefit from opportunities.

Culture A sustainable culture within the company

•

Provided monthly ‘sustainability on site’

will help to lay the foundations to meet the

briefings for site staff via the ‘Esh Safe News’,

challenges we have set the Group. Culture can

and our HSEQ Meetings.

be defined as a combination of commitment, control, co-operation, competence and

Indicators of a positive sustainability culture

communication.

include:

To help us maintain a positive sustainability culture we have: •

Developed an online training course for all Esh Group Apprentices – The Esh Carbon

•

Considerate Constructors Scheme Scores.

•

Number of environmental toolbox talks delivered.

•

Trivselhus by Esh awarded ‘Sustainable Developer of the Year’.

Coach.

•

Committed to providing Site Environmental Awareness Training (SEATS) for all Site Managers.

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Supply Chain Although many of the environmental impacts in

Indicators of our performance on the supply

our supply chain are beyond our direct control,

chain include:

the Group aims to influence our partners to help us both reduce our impact on the environment.

To help reduce the environmental impact of our supply chain we have: •

•

Calculation of our ‘Scope 3’ carbon footprint, and reduction of ‘hot spots’

•

Examples of the specification of alternative materials on schemes

•

Held regular supply chain meetings with top

Case studies detailing reduced transport emissions in the supply chain

suppliers.

•

Brought the supply of recycled aggregate materials ‘in-house’ through our facility in County Durham.

•

Influenced our clients to use more sustainable materials.

Carbon Emissions The Group’s carbon emissions are its most

•

significant environmental impact. In order to meet the targets set by the Industrial Strategy

Indicators of our performance on carbon emissions include:

•

2025, and the 2008 Climate Change Act, we

Group carbon footprint and the carbon intensity of Group Operations.

need to significantly reduce our emissions.

•

To help us reduce our carbon emissions we

•

Progress against meeting a ‘Science Based Target’.

have: •

Invested in a new fleet of HGVs and a Masternaut system for light commercial vehicles

•

Specified energy efficient site accommodation and implemented a requirement for grid connection on all sites, where reasonably practicable.

•

Invested in a real-time gas, electricity and water monitoring system for our Bowburn Complex.

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Emissions saved for our clients, through innovation on our projects.

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Waste Management Construction activities by their nature produce

•

Overhauled waste management in

a lot of waste material. We understand that by

our offices, making it easier for staff to

managing waste smartly, it is possible to reduce

segregate waste.

the amount that is delivered to landfill and to reuse the majority of materials.

Indicators of our performance on waste management include:

To aid our progression to a ‘circular economy’ we have: •

Opened our own waste processing facility

•

Percentage of waste diverted from landfill

•

Landfill tax paid per year

•

Total amount of waste/ £100m turnover

•

Reported environmental near misses, to

for inert materials in County Durham.

•

Started a collaborative approach to waste management with our skip companies.

Environmental Protection Many of our activities take place in environmentally sensitive areas, close to places of special scientific interest or near

learn from our mistakes.

•

watercourses. With the fines for pollution incidents increasing, we need to make sure we

Invested in spill kit/ spill response training for our staff.

•

reduce our exposure to risk. We also take great

Audited all construction sites at least once per month.

pride in working for high profile clients, including Northumbrian Water and the Environment

Indicators of our performance environmental

Agency.

protection include:

To make sure our activities protect the environment we have: •

Involved specialist ecologists on sensitive schemes.

•

Average scores from our HSEQ inspections.

•

Case studies from schemes with a positive environmental impact.

•

Zero prosecutions/ enforcement notices from the Environment Agency.

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