Mott Macdonald Group Ethics Policy Statement

All employees are informed of the anti-bribery policy and their responsibilities as part of their introduction to the company, and we include a copy in their introductory package. We work closely with the construction industry around the world and take over some traditional construction activities in the UK through the JN Bentley business. These activities are covered in a tailor-made statement on modern slavery. This statement confirms our compliance with section 54 of the UK Modern Slavery Act 2015. When establishing our policies and processes, we follow UK Government best practice and guidance on `supply chain transparency`. In addition to posting this statement on the Mott MacDonald Group website, we will also post it on all related websites to reinforce our commitment to this program. To further support the business, we have created best practice guidelines for our project managers and teams to help them identify key areas of risk and implement appropriate controls to mitigate risk. This has been incorporated into our health and safety risk assessment process, and our global safety managers and project security consultants have been trained to support project staff. The identified risk areas can be roughly grouped as follows: We train all our employees in ethics and respect for our values, policies and processes.

We also offer training on human resource management and communication skills that are directly aligned with our PRIDE values. This creates a strong culture of tolerance towards others, transparency in decision-making and mutual respect, which supports our Modern Slavery Training Module, which is available to all employees. The above statement was approved by Mott MacDonald`s Board of Directors and signed on its behalf by James Harris, Group Chief Executive Officer. Our Code – Delivering with PRIDE is our new Code of Conduct/Code of Ethics, which sets out our standards and expectations for all our employees regarding modern slavery and human rights. All employees of the company receive training on our Code and read and certify that they have complied with it. Our Code is made available to our suppliers and through our external website and underlines our desire to only work with those who can meet our standards and expectations, including aspects related to modern slavery and human rights. Our Code helps all those who work for or with us to improve their understanding of modern slavery and to raise concerns if they encounter it. Because we consider the risk of slavery and human trafficking in our own business to be low, we monitor the performance of our suppliers who help us meet our policy commitments and the services they provide to us. We also monitor our own compliance with our employment and procurement processes. In addition, we are audited by third-party organizations worldwide for compliance with our internal business processes as well as for quality standards. We believe this approach is appropriate to manage our risks for our Tier Suppliers.

The policy makes it clear that we expect all employees, regardless of seniority, to uphold the highest standards of openness, honesty and accountability. It also provides employees with clear procedures and assures them that information will remain strictly confidential if corruption or bribery is suspected. The above groups can be subdivided into work, i.e.: We check whether we have up-to-date and accurate information about our suppliers, supported by our supplier questionnaire before commissioning. We verify that they meet the requirements of our modern slavery, ethics and anti-corruption policies, and that they share important financial and structural information with us. After their appointment, suppliers are evaluated annually on the basis of formal proof of performance. This statement applies to the entire Mott MacDonald Group and its global operations, with the exception of our UK-based JN Bentley business. It should be noted that our company in Australia (Mott MacDonald Australia Pty Limited) has also issued a statement on modern slavery under the Modern Slavery Act 2018. Our approach to respecting people and our suppliers is also embedded in our policies on slavery and human trafficking, equality, diversity and inclusion, integrity, human resources, risk management, procurement, protection and social responsibility.

By following our Code, we build stronger, more reliable relationships with our customers, communities, and colleagues and increase our ability to comply with national, state, and local laws and regulations. We comply with local laws and regulations wherever we work. However, if our Code sets out the highest standard, we expect that to be true. We spoke to our more than 50 sector leaders about the risks and issues of modern slavery. We have also committed on an individual basis to consider country-specific risks based on our business and supply chains, which feed into the risk assessment framework. We have built on our existing project management requirements to ensure that modern slavery issues are considered at the outset of relevant projects by adding additional details to help bid teams assess the risk of modern slavery. This includes consideration of industry, country and suppliers A trigger point to get people to consider risk has been built into our existing processes. We are working to strengthen our external engagement with NGOs, competitors, customers and suppliers on modern slavery issues. As a leading global consulting firm, we have a responsibility to leverage our influence by executing some of the world`s largest infrastructure projects to create positive change for those who need it most. Modern slavery and human rights were key themes of our Code under the theme “Respect for Human Rights.” Additional resources were provided to support learning and understanding, including a number of dilemmas for discussion, frequently asked questions, and do`s and don`ts.