How we manage ESGS governance
We are a responsible business and comply with legal requirements of the countries where we operate. Responsible conduct is a critical element of our corporate culture and embedded in our strategy. We operate with the highest degree of integrity and ethics.
Our responsibilities
It is our responsibility to conduct our business ethically, taking into account our ESGS purpose and being a good employer. We have a strong governance structure in place; the Modulaire executive team and Board of Directors take ESGS commitments seriously and seek to deliver strategy and targets in a way that our stakeholders can be proud of.
Delivering our commitments
Our commitments to ESGS are championed at every level of Modulaire, from our shareholders, Board, senior leaders, and management teams to all our customer service centres.
We deliver on these commitments by incorporating them into key processes including our business performance reviews, assurance audits and risk management. It enables us to assign the appropriate level of accountability to meet our objectives and KPIs.
Climate Change governance
The executive and management responsibility for assessing and managing climate-related risks and opportunities is held at board level.
Modulaire ESGS Report 2024
Governance structure for ESGS
Board of BCP V Modular Services Holdings Limited
(including independent non-executive directors)
Provides ESGS oversight (including climate change) and approves material initiatives, disclosures, and reports. Board oversight of climate-related risks and opportunities.
Environment, Social, Governance and Sustainability (ESGS) Committee
Brookfield-nominated member, Group CEO, Group General Counsel, Director ESGS, and Group Chief Human Resources Officer
Responsible for assisting the Board in articulating and developing our ESGS strategy, mission and tactics. It provides oversight of sustainability initiatives, in line with our purpose, values and strategy. The committee oversees ESGS monitoring of material risks and opportunities (including climate-related), disclosures, reporting, operations, policies and regulation. The Group General Counsel and Director of ESG and Sustainability are responsible for the ESGS function, policy and strategy and ensure implementation and the provision of necessary resources.
Audit and Risk Committee
Responsible for oversight of the Group’s compliance with the Corporate Sustainability Reporting Directive.
Executive Committee
Develops and implements ESGS plans for our Strategic Business Units (SBU) and local policies. Responsible for developing and executing ESGS mandate and initiatives. Reviews objectives and progression of our ESGS policy, procedures and projects.
ESGS Team and Working Group / Forum
From each SBU: ESGS Managers and relevant function leads e.g. Operations, HR, Finance
Responsible for executing ESGS mandate and initiatives outlined by the ESGS Committee.
Human rights commitments and policies
Our commitments
Modulaire is committed to protecting human rights across its operations and supply chain, including for our employees, onsite contractors, suppliers, customers and in communities where we operate. We are also committed to ensuring that modern slavery or human trafficking is not taking place in our supply chain or in any part of our business. We further these commitments by implementing and enforcing effective policies, systems, controls and programmes. We are signatories of the UNGC and run activities on associated UN days across the Group (page 30). Read our Modern Slavery and Human Trafficking Compliance Statement here: www.modulairegroup.com/modern-slavery-act
Assessing our risks
Our modern slavery risk assessment considers three key factors: vulnerable populations; high-risk sectors; and high-risk geographies. Based on these risk factors, we identified there are varying levels of modern slavery risk exposure across our business:
1. Our suppliers:
we can potentially be exposed to modern slavery risk if it is present in our supply chain, for example, through goods from high-risk countries or base-skill workers engaged in high-risk category services such as cleaning or building maintenance. Based on our supply chain profile, the risk of modern slavery in direct suppliers remains relatively low. We recognise that the risk of modern slavery may increase further down our supply chain (Tiers 2 and below) where we have lower visibility and generally lower ability to influence.
2. Our people:
we can potentially be exposed to modern slavery risk as an employer. However, as the majority of our workforce is directly employed, the risk of causing modern slavery in our role as an employer is low.
3. Our Customers:
there may be a risk of exposure to modern slavery through leasing services, for example, units provided to clients operating in sectors with base-skill labour and long complex supply chains can present a higher risk of exposure to modern slavery, for example, in construction.
1. Governance
2. Key policy framework
- Anti-Bribery and Corruption Policy
- Code of Ethics
- Cybersecurity Policy
- EDI Policy
- ESGS Policy
- Gift and Entertainment Policy
- Health & Safety Policy
- Modern Slavery & Human Trafficking Compliance Statement
- Policy on Electrification of Machinery, Forklifts & Vehicles
- Policy on Sustainable Use of Water
- Policy on Waste Management
- Responsible Sourcing Policy
- Speak-Up Policy
- Supplier Code of Conduct
- Sustainability-Linked Financing Framework
3. Key systems and controls to mitigate human rights risks across our supply chain
Our Suppliers
Our People
Customers
- Modern Slavery Statement
- Training: Code of Ethics, Anti-Bribery, ESGS Awareness
- Supplier Code of Conduct
- Responsible Sourcing: Screening, Assessment and Due Diligence
- Raising Concerns: Whistleblowing Hotline
- Continuous Improvement
Risk mitigation
Our double materiality assessment is outlined in this report and has raised salient human rights issues, which are addressed through our ESGS strategy (page 20, ref: S1-S5, G1-G5). Where risk is identified during our ESGS due diligence assessment, our people will identify lessons or opportunities for improvements to be shared with the procurement team, ESGS Committee and the Board as necessary. Where issues are identified, we agree corrective actions between the relevant parties, documenting the process and outcomes.
Supplier Code of Conduct
The Supplier Code of Conduct reflects Modulaire’s commitment to act ethically and with integrity in all business relationships. To ensure our suppliers and contractors comply with these values, we require them to adhere to the code including a commitment not to use slave labour or participate in human trafficking. New suppliers must agree at on-boarding stage, understanding that our trading relationship may be discontinued if they should fail to comply.
Continuous improvement & measurement
We are committed to the continuous improvement of our supplier governance framework and process controls. This year, Algeco UK received a score of 91% on the Modern Slavery Statement and Modern Slavery Assessment Tool, achieving the UK Government's green category for public sector organisation suppliers.
Demonstrating responsible governance
Modulaire Group is committed to doing business responsibly to maintain trust and respect. We seek to continuously improve our governance approach and procedures, listening to stakeholder feedback and acting on it. We raise awareness of our ESGS policies, strategy and disclosure frameworks to help deliver them. Our performance is audited and shared with the wider community to offer insight, contribute to best practice and help inspire others.
Modulaire Group fosters an inclusive and collaborative working environment by focusing on well-being and support, empowering colleagues to perform at their best and recognising their contributions.
Sourcing responsibly
We depend on our suppliers and the goods they produce to make our own. To understand more about the ESG impacts of their work, we have introduced the Modulaire Group ESGS Responsible Sourcing Policy and programme. Its purpose is to ensure collaboration with suppliers, embed ESGS at all stages, review ESGS performance, improve our knowledge, drive continuous ESGS improvement and provide a safe, inclusive, diverse and motivating environment across our value chain. In addition, we have implemented a new Responsible Sourcing screening process to help us conduct due diligence for new and existing suppliers.
Modern Slavery Assessment
Algeco UK achieved a score of 91% on the Modern Slavery Statement and MSAT (Modern Slavery Assessment Tool), achieving the UK Government’s green category for public sector organisations’ suppliers.
Impacts, Risks, and Opportunities
Type
Cybersecurity, Business conduct and ethics
IRO
Negative
Strategy
Governance
Policy
Ethics
ESGS
ABC
Code of Conduct
IT Policies
Action
Training
Ratings
Certification of 14001
Target
ISO 14001 Service Centres 100% by 2026
12 EcoVadis
Progress on our Governance KPIs
We have achieved all four of our Governance 2024 KPIs.
KPI
Progress
Status
CSRD-ready
Achieved
Progress Cybersecurity and ABC training
Achieved
Implementation of Biodiversity Policy
Achieved
Increase EcoVadis ratings to 10
Achieved
Key
Achieved
Ongoing
Not achieved
Inspiring our people
We operate programmes for safety, resource efficiency, renewable energy and ESGS awareness, which are vital to delivering our ESG strategy. They raise discussion around our shared goals and the reasons behind them. We encourage active participation to support continuous improvement. Our ESGS team runs a regular online ESGS Forum, open to all employees, to learn and share more about our priorities, activities and best practice.
Stakeholder Engagement
We maintain an ongoing commitment to transparent and effective stakeholder engagement, ensuring that all relevant groups are actively involved in shaping our business activities. By integrating stakeholder feedback into our daily operations and decision-making processes, we align our strategies with their evolving needs and interests.
Our stakeholder groups include:
- Public and social stakeholders: Local communities, media, general public, federations, NGOs, and academic institutions
- Operating and business environment: employees, suppliers, producers, government and public authorities, customers and consumers.
- Financial stakeholders: Shareholders and investors
This approach strengthens collaboration, fosters trust, and supports sustainable business growth.
Training
Anti-Bribery and Corruption training is a requirement for all of Modulaire’s workers and in 2024, the following was delivered:
Cybersecurity training
117 hours
Code of Ethics training incl. Anti-Bribery & Corruption
2,070 hour
ESG management systems
We achieved ISO 14001 certification of our Environmental Management System at all design and assembly facilities and are working to achieve coverage at all sites (2024: 62% sites).
Policy updates
We update our policies and documentation to ensure compliance and for continuous improvement. In 2024, Modulaire Group updated:
- Biodiversity and Climate Change Adaptation Protocols
- Electrification policy
Sustainability ratings
We have achieved 11 EcoVadis sustainability ratings this year (6 gold medals and 5 silver medals). The evaluation involves a review of ESG performance in four key areas: Environment, Ethics, Labour & Human Rights, and Sustainable Procurement. A gold rating means EcoVadis has rated the business in the top 5% of 100,000+ companies in 175+ countries and 200+ industries.
Responsible sourcing in action
Our Procurement team ensures the goods we buy are safe, efficient, high-quality, and fairly priced. We also promote environmental and social responsibility by encouraging suppliers to adopt sustainable practices and develop greener products.
We expect our suppliers to operate fairly and with integrity, following ethical business standards. Our Responsible Sourcing Policy is helping us to strengthen relationships with our direct suppliers.
Responsible sourcing, or Sustainable procurement, means considering environmental, social, and economic factors when choosing goods and services. The goal is to reduce negative impacts while making positive contributions in the short, medium, and long term through ethical and sustainable sourcing.
Modulaire Group’s Responsible Procurement Policy focuses on working with suppliers across the value chain to embed Environmental, Social, Governance, and Sustainability (ESGS) at all stages. We review ESGS performance regularly, improve our understanding of the supply chain, and drive continuous improvement. While our approach does not cover every possible situation, it defines key expectations for suppliers and partners to uphold our high standards.
Repurposing flooring
We want to continue enhancing the circularity of our modular units. Our teams work hard to reuse materials, finding new ways to maximise their value through supplier partnerships. For the past three years, Algeco in Poland has participated in the Tarkett ReStart® flooring take-back and recycling program. It has proven an effective way to repurpose flooring that is returned to us during the refurbishment cycle of our modules. Since 2022, 55 tonnes of flooring has been collected by the Algeco team and recycled by Tarkett at their factory in Sweden, saving 236.5 tonnes of CO2 emissions. New flooring is then installed inside our modular units. In 2024, the process was documented on video by Tarkett to demonstrate the key stages of the circular process: removal and sorting of old PVC flooring; its preparation for recycling; and the application of new flooring inside Algeco’s modular units.
Impacts, Risks, and Opportunities
Type
Procurement
IRO
Negative
Strategy
Responsible sourcing
Policy
Responsible Sourcing
Anti-Bribery and Corruption Policy
Code of Ethics
EDI Policy
ESGS Policy
Gift and Entertainment Policy
Health and Safety Policy
Modern Slavery and
Human Trafficking Compliance Statement
Action
5 year procurement plan
Target
Assessment of T1 High spend by 2027