Introduction

The purpose of this statement is to confirm that Pinnacle Group Ltd and other relevant group companies¹ (“Pinnacle”) have taken appropriate steps during the year ending 31st March 2025 to ensure our continued compliance with the Modern Slavery Act 2015 (the “Act”). As a business we are committed to providing employment opportunities which are non-discriminatory, support living wage legislation, and offer regular hours and working conditions that are safe and hygienic. We are also committed to implementing and enforcing effective systems and controls to ensure that there is no modern slavery or human trafficking taking place anywhere in our own business or in any of our supply chains.

[1] This statement covers all subsidiaries of the group, but particularly Pinnacle Group Ltd, Pinnacle Housing Ltd and Pinnacle FM Ltd who each fall within the scope of section 54(2) of the Modern Slavery Act 2015.

Our Group

Pinnacle is a market-leading national provider of integrated housing, neighbourhood and workplace services. With over 30 years of experience, we deliver expert, place-based management and maintenance solutions that enhance the everyday lives of the communities we serve. Over three decades we have become a trusted service delivery partner of Government and public authorities, institutional investors, housing associations, housebuilders and businesses.

We now directly employ over 3,800 people of more than 70 different nationalities, operating from over 200 locations across the UK. Our service infrastructure allows us to “localise” service delivery and be a part of the communities we serve.

Further business information can be found at: www.pinnaclegroup.co.uk.

Pinnacle is heavily reliant on its people and supply chains in the delivery of services. We are also aware of our diverse customer base with a wide range of backgrounds and needs. Each business within the Group is responsible for ensuring that they can demonstrate compliance with the Act by working to our Code of Conduct and Group policies and procedures.

Due diligence across our business and supply chain

Our governance in relation to slavery and human trafficking

Pinnacle has a reputation for and prides itself on being a moral and principled employer. We believe this provides a platform to deliver a more consistent service and quality across our contracts and sends out a message that we care about the wellbeing of the people working for us.

We support living wage requirements and regularly review our terms of employment to ensure that they comply with all relevant legislation. We are accredited as a Recognised Service Provider by the Living Wage Foundation.

We have an in-house recruitment model. Agencies are used by exception, and we have procured a preferred supplier list of reputable employment agencies. The practices of agencies are verified before accepting workers from that agency.

All staff employed by Pinnacle have identity and Right to Work checks, employment reference checks, and where applicable Disclosure and Barring Service (DBS) and Baseline Personnel Security Standard (BPSS) checks prior to employment commencing. These checks are always carried out in line with the relevant legislation and in accordance with UK Government guidance. For certain roles, where additional background checks are required, a more in-depth vetting process is in place.

Our HR and Payroll system provides us excellent transparency in this area, through extensive DBS workflows and reporting to incorporate 3-yearly checks, significantly reducing any compliance risk.

We are an accredited “Investor in People”, holding Silver status. The accreditation requires a rigorous internal and external assessment to ensure our policies, procedures, and the way we treat our staff sets a standard of a great employer, and an outstanding place to work.

We expect all staff to adhere to the Group’s Code of Conduct. We ensure that we have systems in place with an overarching policy statement as well as a whistleblowing policy to encourage the reporting of concerns and the protection of whistle blowers.

Our supply chain in relation to slavery and human trafficking

We have zero tolerance to slavery and human trafficking. We expect our suppliers to work to the same high standards that we impose on ourselves. We actively promote safe and fair working conditions, including the responsible management of environmental and social issues within our supply chain.

As part of our online supplier onboarding process, all suppliers are required to complete various due diligence checks and agree to our Supplier Code of Conduct (“Code”). We assess our supply chain for potential areas of risk of non-compliance with the Act, considering a number of factors including:

• Suppliers operating outside of the UK / EU regulatory framework;
• Raw materials that are produced, or likely to be produced, outside of the UK / EU; and
• Suppliers operating using temporary and/or low skilled labour.

Our standard supplier contracts incorporate the Code, which includes key modern slavery provisions. Suppliers are required to fully support and operate in accordance with the Act and take all reasonable steps to ensure that there is no modern slavery in its business or supply chain. Pinnacle reserve the right to terminate any supplier relationship where this obligation is not adhered to. All suppliers need to reconfirm their details annually and confirm acceptance of our Code.

During the year we introduced a new supply chain management system which automatically flags suppliers that should have a modern slavery policy and/or publish an annual transparency statement.  We completed assurance audits with our strategic suppliers where the management of environmental and social issues was addressed as an agenda item for discussion. All were able to produce their transparency statement when requested.

Effectiveness in ensuring that slavery is not taking place

Pinnacle has a set of policies and procedures which in general cover human rights issues and are aimed at minimising the risk of slavery or human trafficking.

In addition to our Modern Slavery Policy, some of the policies and procedures of particular note are our staff Code of Conduct, Supplier Code of Conduct, Recruitment and Selection Policy, Anti Money Laundering Policy, Anti-Fraud, Bribery & Corruption Policy and Whistleblowing Procedure. These are all easily available on our intranet and upon request.

Our staff, customers and suppliers are actively encouraged to report any concerns or suspicions they have that any unlawful conduct, including slavery or human trafficking, is taking place at work. For our staff, we have a dedicated and confidential Report a Concern link on our intranet to facilitate this.

We also promote the Modern Slavery Helpline 0800 0121 700 (www.modernslaveryhelpline.org/), where individuals can report any suspicious activity or seek help and advice in confidence.

In an effort to combat the hidden nature of modern slavery and boost awareness of the signs, we display posters and infographics created by the UK Home Office (part of the ‘Modern slavery is closer than you think’ briefing documents) in company offices, site depots and customer facing notice boards. Our regular internal communications provide links to a UK Home Office short film and other relevant information to further educate the business. Looking ahead, we will continue to broaden the accessibility of our resources such as providing information in different languages.

Staff training about slavery and human trafficking

Our policies are communicated to staff from the point of induction and regular updates are provided as required either through training programmes or Corporate Communications as the group sees fit. All staff are signposted to our Core HR policies and Code of Conduct at induction.

Our policies and procedures are reviewed on an annual basis, or more frequently where legislation or regulation updates dictate, to ensure that they remain fit for purpose. Of particular relevance are our policies on safeguarding and vulnerability issues, mindful of our diverse customer base and workforce.

To boost awareness, we again marked this year’s Anti-Slavery Day with a communications campaign addressing what is modern slavery and how to spot signs. The article also spotlighted our policies, procedures and provided contact details in the event of an employee wanting to raise a concern.

We will continue to provide awareness training for all staff, and tailored training for key staff and managers.

Our Commitment

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Pinnacle’s slavery and human trafficking statement for the financial year ending 31st March 2025 as approved by the Board of Directors.

Perry Lloyd

Group Chief Executive