Modern Slavery and Human Trafficking Statement

Approved by the Prime Board (April 2026)

Introduction

In accordance with its obligations under the Modern Slavery Act 2015 (the “Act”), Prime plc (“Prime”) makes the following statement relating to Prime and its subsidiaries (the “Group”) in respect of the Group’s financial year ended 31 December 2025.

This statement sets out the steps the Group has taken, and is proposing to take, to address the risk of slavery and human trafficking taking place in its business and within its supply chain.

Our Business and Organisational Structure

Prime is a property development company. We operate throughout the UK in the health and social care real estate sector with clients including both private and public sector organisations. Our corporate social responsibility objectives aim to improve the impact of our business on society and the economies of the areas in which we work, as evidenced by our B Corps accreditation.

Prime is committed to always working to the highest professional standards and complies with all the laws, regulations and rules relevant to our business. We have a zero-tolerance approach to slavery and human trafficking.

Prime’s wholly owned subsidiary, Prime (UK) Developments Limited, employs 43 staff who work mainly from our head office in Worcester. All Prime staff work flexibly between home and the office and receive in excess of the minimum/living wage. There have been no instances of modern slavery or human trafficking amongst our employees.

We have identified the areas at high risk of slavery or human trafficking to be in the construction and property maintenance industries, with whom we deal on a regular basis as part of our business and supply chain.

We have adopted a Modern Slavery Policy which is one of a number of policies which confirm our commitment to being an ethical, sustainable and responsible business. We are proud to have achieved B Corps accreditation, which emphasises our commitment to deliver position change in the world through the projects which we develop. We expect the same standards from those we work with and are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

Our Executive Committee has responsibility for ensuring our Modern Slavery Policy is complied with and to manage any breaches or concerns. In addition, we have a Whistleblowing Policy and if there are any concerns about any wrongdoing or breaches of law, these concerns can be raised in confidence and without fear of disciplinary action.

Our Policies

In addition to the policy mentioned above other policies adopted by the organisation relevant to the identification of modern slavery and human trafficking risk include:

Recruitment Policy
Environmental Policy
Anti-Corruption and Bribery Policy
Health and Safety Policy
CSR Policy
Building Contractor Procurement Policy
Prime HQ Purchasing Policy

Supplier Due Diligence

Our procurement processes include undertaking appropriate due diligence before a new supplier is approved. New suppliers in the construction and property maintenance sectors will be required to comply with International Labour Organization (ILO) principles in relation to human rights and conditions of employment, plus all local and national laws and regulations and confirm that they have modern slavery, human trafficking and anti-bribery and corruption policies commensurate to that of Prime or will adhere to our policy where they do not have their own.

Supplier responses will be considered when short-listing for the award of contracts or selection to a framework and any concerns made known to them. Should any supplier fail to meet our standards or be unwilling to answer any questions we will cease to engage with them.

As we have identified the construction industry supply chain as being a material risk, Prime will include contractual clauses in its building contracts with its principal contractors (and require them to ensure compliance by their sub-contractor supply chains) to ensure policies are in place to prevent human trafficking and modern slavery. Appropriate rights to audit compliance periodically will be sought where appropriate, with a focus on areas deemed to be at high risk.

Training