Modern Slavery and Human Trafficking Statement

SECTION ONE: Introduction

This Statement is made pursuant to section 54 of the Modern Slavery Act 2015 and relates to the financial year ending 31 December 2025. This Statement covers all companies within the Heavy Haul Rail Limited Group, in particular those entities, which under the Modern Slavery Act 2015, are mandated to publish an annual Modern Slavery Statement:

This statement has been approved by the directors of the Heavy Hail Rail Limited.

SECTION TWO: Our Organisation’s Structure

Heavy Haul Rail is an established provider of heavy haul rail freight logistics solutions, operating services across the entire UK and parts of Continental Europe, employing over 940 employees. Our ultimate beneficial owners are investor Brookfield Infrastructure and Singapore’s state owned GIC. 

SECTION THREE: Our Policy on Slavery and Human Trafficking

Consistent with Heavy Haul Rail’s core values, which relate to respect and integrity, our Modern Slavery and Human Trafficking Policy reflects our commitment to acting ethically in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We continuously review and update all our policies.

SECTION FOUR: Our Supply Chains

In the United Kingdom, Heavy Haul Rail has over 1100 suppliers across a wide range of sectors, including the rail infrastructure operator (Network Rail), engineering suppliers, fuel suppliers, road transport suppliers, port companies, asset lessors, information technology service providers, insurance and facilities management companies. In addition, the firm works with a number of professionals, consultants, and contractors.

We believe those areas which give rise to the highest modern slavery risk are: 

As part of our initiative to identify and mitigate risk we have in place systems to:

SECTION FIVE: What Have We Done?

Supplier Adherence to our Values and Ethics

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a requirement for each new Supplier to agree to adhere to our Supplier Code of Conduct and Sustainability Charter.

We have a compliance team, which consists of involvement from the following departments:

To effectively promote Modern Slavery legislation our supplier conditions of trading clearly state our expectations that our suppliers will comply with the modern slavery legislation and affirm our intention to step away (without penalty) if any occurrences of non-compliance with modern slavery legislation is found.

When onboarding a new supplier, we ask the suppliers to sign that they have understood and support our Code of Ethics and Sustainability Charter, and we track on an annual basis that those suppliers with a spend over £250K have a modern slavery statement (available on their website).

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. We also require our business partners to provide training to their staff, suppliers and providers.

Our Effectiveness in Combating Slavery and Human Trafficking

Further Steps

We continually review the effectiveness of our compliance processes with respect to modern slavery and human trafficking, and we welcome the opportunity to collaborate with third parties and employees to eliminate the risk of improper business practices or conduct across our business operations. In the next financial year, we intend to enhance our supplier vetting procedures and will implement a KPI metric to score and verify high value or high-risk vendor Modern Slavery compliance. 

Effectiveness of Our Procedures

In the financial year to 31st December 2025, there were no reported breaches relating to modern slavery made to our whistleblowing hotline, nor any instances of remedial action being required with respect to any of our suppliers. We continually review our systems and controls to assess how effective we have been in ensuring that there is no slavery or human trafficking in our supply chains and will make improvements and changes where necessary.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Group’s slavery and human trafficking statement for the financial year ending 2025.

Dave Penney,
CEO Heavy Haul Rail Limited

23 January 2026