Modern Slavery Statement

Financial year ending 31 March 2026 · Published 15 May 2026

1. About Atreeum

Emanja Ltd (trading as Atreeum) is a UK company developing rural villages of off-site manufactured, energy-positive homes. Our headquarters is in Suffolk. As of the date of this statement we have a small founding team, no completed villages, and no homes yet sold. Our first village is at the early-stage council-engagement phase in the East of England.

This statement reflects the steps we have taken, and intend to take, to identify and prevent slavery and human trafficking in any part of our business or supply chain.

2. Our supply chains, current and planned

At the date of this statement our operational footprint is limited. The supply chains we will rely on as we scale, however, sit in some of the higher-risk sectors documented by the UK Home Office, the International Labour Organization, and independent researchers. We are publishing this statement now so that the policy is in place before those supplier relationships are entered into.

Supply chain risks we are alive to

• Solar photovoltaic modules. A substantial share of global polysilicon production is concentrated in the Xinjiang region of the People's Republic of China, where credible reports (including from the UK Foreign Affairs Committee and the US Department of Labor) have documented state-imposed forced labour involving Uyghur and other minority workers. We will not knowingly source modules whose silicon supply chain cannot be traced upstream of this region. We expect to require Solar Stewardship Initiative (SSI) certification, equivalent third-party traceability, or sourcing from non-PRC origins (e.g., the United States, Vietnam, India, the European Union) from every PV supplier.
• Battery storage and electric vehicles. Cobalt, nickel, and lithium supply chains have documented risks of forced labour, child labour, and unsafe working conditions, particularly in cobalt mining in the Democratic Republic of the Congo. We will require battery and EV suppliers to evidence Initiative for Responsible Mining Assurance (IRMA) auditing or equivalent due diligence on their mineral inputs.
• Off-site manufacturing labour. Modular and off-site construction relies heavily on factory-floor labour, and migrant-worker exploitation has been documented in this sector in both the UK and abroad. We will only contract with manufacturing partners who hold Gangmasters and Labour Abuse Authority (GLAA) licences where applicable, evidence direct employment (not agency intermediation) of their factory workforce, and consent to on-site audits.
• On-site construction labour. Site groundworks, foundation works, and connection to utilities are typically carried out by subcontractors. The construction sector has a long-standing risk profile for labour exploitation, particularly involving non-UK migrant workers. We will contractually require all site contractors to comply with the Modern Slavery Act, to evidence right-to-work checks, and to ensure that their own sub-contracting is similarly compliant.
• Cleaning, landscaping, and other services at completed villages. Once villages are operational, ancillary service contracts (cleaning, landscaping, maintenance) sit in a sector with known modern-slavery risks. We will require all service contractors to evidence GLAA compliance and ethical recruitment.
• Software and digital services. Lower-risk, but not zero-risk. Suppliers of cloud infrastructure, payment processing, and developer tools are predominantly large publicly-listed companies with established modern-slavery statements of their own. We satisfy ourselves of that on selection.

3. Our policies

We have adopted the following policies and they apply to every person who works for, with, or on behalf of Atreeum:

• Zero tolerance. We will not engage with any supplier, contractor, or business partner that we have reasonable grounds to believe is involved in modern slavery or human trafficking.
• Supplier code of conduct. Every supplier we contract with from this date onwards will be required to confirm in writing that they comply with the Modern Slavery Act 2015 and the standards set out in this statement, and that they pass equivalent obligations down their own supply chain.
• Whistleblowing. Anyone (employee, contractor, member of the public, rooter) who suspects modern slavery in any part of our operations or supply chain can report it in confidence by emailing hello@atreeum.co.uk with “Modern Slavery” in the subject line. We will investigate and we will not retaliate.
• Recruitment. Atreeum recruits directly, pays at or above the Real Living Wage as set by the Living Wage Foundation, and does not use unregulated labour-supply agencies.

4. Due diligence

Before entering into any contract with a supplier in the higher-risk categories above, we will:

• Require a written statement of their modern-slavery practices, and where applicable a copy of their own section 54 statement.
• Verify the relevant third-party certifications (SSI, IRMA, GLAA, or equivalent).
• Include modern-slavery clauses in the contract, requiring compliance, audit rights, and the right to terminate for breach.
• Document the assessment in the supplier file and review it annually.

We recognise that no due-diligence process is perfect and that some suppliers will deal honestly with us at the contractual level while their own deeper-tier suppliers may not. Where we identify such a risk we will require remediation or change suppliers.

5. Training

While the team remains small, every person involved in supplier selection has read this statement and has access to the Home Office statutory guidance on modern slavery (the “Transparency in Supply Chains” guidance, updated September 2023). As we hire, we will deliver formal modern-slavery training within the first 30 days of employment to anyone whose role involves procurement, recruitment, site management, or supplier engagement.

6. Effectiveness

We measure our effectiveness against the following indicators, recognising that until we have active supplier relationships several of these will read “not yet applicable”:

• Percentage of suppliers in higher-risk categories with a signed Supplier Code of Conduct on file.
• Percentage of solar PV procurement covered by SSI certification or equivalent traceability.
• Percentage of battery and EV suppliers covered by IRMA-equivalent mineral due diligence.
• Number of modern-slavery whistleblowing reports received and the actions taken in response.
• Number of supplier contracts terminated or refused for modern-slavery reasons.

From the financial year ending 31 March 2027 we will publish these figures in the annual update of this statement.

7. Forward commitments

By the end of the next financial year (31 March 2027) we commit to:

• Have a written Supplier Code of Conduct, derived from the Ethical Trading Initiative Base Code, that every new supplier signs.
• Have completed first-pass due diligence on every solar PV, battery, and modular-construction supplier we have engaged.
• Publish the updated statement with the first set of measured indicators.

8. Review

This statement will be reviewed and republished annually. The version on atreeum.co.uk is the current and official version. Earlier versions are retained internally and can be requested by emailing hello@atreeum.co.uk.