Modulaire Group is committed to responsible business, upholding trust and respect as guiding principles. Throughout our circular business model, we embed governance as a continuous cycle of accountability, transparency and improvement.
Modulaire ESGS Report 2025
Actions for Governance
Steady progress continues to be made; we are embedding core ESGS processes, including business performance reviews, assurance, and risk management. This approach strengthens accountability, and our results demonstrate encouraging progress. We remain determined to accelerate delivery against our stated commitments.
Sustainability ratings
As demand for sustainable goods and services grows, our customers increasingly ask for trusted sustainability ratings. In a recent survey of nearly 500 Algeco customers in the DACHS region, 51% rated sustainability rankings as ‘important’ or ‘very important’ for their business, while only 12% considered them unimportant - showing they deliver value to our customers.
The EcoVadis assessment includes a review of ESGS performance in four key areas: Environment, Ethics, Labour & Human Rights, and Sustainable Procurement. Overall, our sustainability rating, based on EcoVadis scores, has slightly improved with more regions moving into the Platinum and Gold categories and reflecting our commitment to ESGS continuous improvement.
In 2025, we achieved 12 ratings:
- Platinum rating: Advanté, Italy, Netherlands, Spain;
- Gold rating: Belgium, Germany, Poland and UK;
- Silver rating: Australia, France and Nordics; and
- Bronze rating: Altempo.
Platinum is the highest possible rating given by EcoVadis and signifies that a company is ranked in the top 1% of all businesses they have assessed, whilst a Gold rating is ranked as top 5%, a Silver rating as top 15%, and a Bronze ratings as top 35%.
Progress on our Governance KPIs
We have achieved three of our four Governance KPIs in 2025.
KPI
Progress
Status
CSRD-ready
Legislative delay
Progress Cybersecurity and ABC training
Achieved
Implementation of Biodiversity Policy
Achieved
Increase EcoVadis ratings to 12
Achieved
Key
Achieved
Ongoing
Not achieved
ESG management systems
Modulaire Group continues to expand ISO 14001 accreditation across our sites, recognising the advantages it offers for environmental management governance. At present, we have 74% coverage and over the next year our target is to achieve 80%.
Stakeholder engagement
We engage with stakeholders to understand their expectations and the impacts of our sustainability strategy. Feedback is integrated into our governance processes, creating a loop-back mechanism where insights inform risk assessments, strategy development, transition planning, double materiality assessments, supplier assessments and investor relations.
We hold regular ESGS Forums, attended on average by 200 employees from across the organisation, where external speakers are invited from customer organisations, suppliers and community groups. Our employees participate in talks and speaking engagements at conferences and academic institutions (page 55).
Training
The Group focus on key material topics includes a range of courses for all computer users, delivered through online training and managed by the Legal and IT departments. In 2025, employees completed 4,955 hours of Cybersecurity training and 3,765 hours of Code of Ethics and Compliance training, which included 483 hours on Diversity, Equity, and Inclusion.
Modern Slavery Assessment
Algeco UK achieved a score of 81% on the Modern Slavery Statement and MSAT (Modern Slavery Assessment Tool), achieving the UK Government’s green category for public sector organisations’ suppliers.
CSRD preparation
We have completed a gap analysis of the Corporate Sustainability Reporting Directive (CSRD) and will perform an updated double materiality analysis ahead of reporting requirements under the revised CSRD legislation. We have also started working on the interoperability of disclosure requirements, incorporating ASRS and UK TPT.
Policy updates
In 2025, we updated our ESGS Policy and introduced a new Biodiversity Policy, Climate Change Adaptation Protocols and Climate Change Scenarios to reflect recent developments in the ESGS context. ESGS commitments are promoted across Modulaire from the Board and senior leaders to management teams and customer service centres.
Impacts, Risks, and Opportunities
Type
Cybersecurity, business conduct, ethics & assurance
IRO
Negative
Strategy
Governance
Policy
Code of Ethics
ESGS
IT Policies
Code of Conduct
Anti-Bribery and Corruption
Action
Training
Ratings
ISO 14001 coverage
Target
12 EcoVadis ratings
ISO 14001 80% coverage
Cybersecurity 4000 hrs training
Embedding sustainability through strong governance
We are a responsible business and adhere to the legal requirements of the countries where we operate. Responsible conduct is a critical element of our corporate culture and embedded in our strategy.
Sustainability Governance Overview
We operate with the highest degree of integrity and ethics. As good employers, it is our responsibility to conduct our business ethically, with consideration for our ESGS purpose, as we grow and succeed together. We have a strong governance structure in place. The Modulaire executive team and Board of Directors take their commitments seriously and seek to deliver on our strategy and targets in a way that our employees, customers, shareholders, and suppliers can be proud of. Our commitments to ESGS are championed at every level of Modulaire, from our investors, Board, senior leaders, and management teams to all our service centres. We deliver on our commitments by incorporating them into key processes, including business performance reviews, assurance audits and risk management. It enables us to assess risks and opportunities and to assign the appropriate level of accountability to meet our objectives and KPIs.
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 49).
Read our Modern Slavery and Human Trafficking Compliance Statement here:
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
- Biodiversity 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
Our customers
- Modern Slavery Statement
- Training: Code of Ethics, Anti-bribery & Corruption, ESGS awareness
- Supplier Code of Conduct
- Responsible Sourcing: Screening, Assessment and Due Diligence
- Responsible Sourcing Handbook
- 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 28, 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 81% on the Modern Slavery Statement and Modern Slavery Assessment Tool, achieving the UK Government’s green category for public sector organisation suppliers.
Responsible procurement
Responsible procurement ensures that all goods and services purchased are safe, efficient, high-quality, and fairly priced, while embedding environmental and social responsibility into procurement practices. It remains complex due to global supply chain dynamics, differing regulatory requirements, and the need for continuous improvement in transparency and performance.
Key action: Responsible Sourcing Policy
We rely on our suppliers and their products and services to deliver our own. In 2025, to strengthen oversight of our ESGS impacts across the value chain, we introduced the Modulaire Group ESGS Responsible Sourcing Policy which embeds environmental, social, governance, and sustainability principles at every stage of the procurement process. Regular reviews are undertaken to monitor performance, strengthen accountability, and drive continuous improvement. The policy is aligned with the European Sustainability Reporting Standards and UK procurement requirements, setting clear expectations for suppliers and partners to comply with legislation and established frameworks. While not exhaustive, this approach provides a consistent foundation for responsible procurement, transparency, and resilience across operations and supply chains.
In 2025, we screened suppliers against our ESGS criteria, covering the top 80% of our spend, and received responses from 46%. We plan to transition to a third-party platform to improve efficiency and broaden coverage. These measures are designed to embed ESGS expectations at every stage of the sourcing process, support collaboration with suppliers, review performance, build knowledge and drive continuous improvement. In 2026, we will pilot a UN Global Compact ESGS supplier training programme to build capability across our supply chain further.
Key action: Responsible Sourcing Handbook
In 2025, Modulaire Group introduced a new Responsible Sourcing Handbook to help suppliers contribute towards value chain good practice.
Developed over two years by the ESGS and Purchasing teams, the handbook aligns with our latest policy and supplier screening process, addressing evolving customer expectations and future legislation. It encourages sustainable and low-carbon practices, supports progress towards Net Zero emissions, and provides suppliers with clear guidance on ESG requirements and processes, raw material risk areas, and practical tools such as checklists.
The handbook is simply written and direct. It has been translated into several languages and provides our suppliers with clear guidance on both what to do and how to do it in order to meet our ESGS requirements. It is publicly available through Modulaire’s website, extending its benefits to the wider business community and reinforcing collaboration across the value chain.
Customer satisfaction
We conduct regular customer satisfaction surveys to assess the quality, accessibility and performance of our products and services across the SBUs. Feedback is being collected on key topics such as service delivery, responsiveness, product reliability and overall customer experience. Survey results will be analysed to identify material impacts, emerging risks and opportunities for improvement. Insights are shared with relevant teams and integrated into operational planning, product development and continuous improvement processes.
Social enterprises
To deliver our modular spaces and services, we work a number of social enterprises (see page 15), offering our customers the same specifications (or better), whilst making a positive impact for social good. These partnerships deliver benefits for all parties, and each product generates a Social Return on Investment.
Impacts, Risks, and Opportunities
Type
Procurement
IRO
Negative
Strategy
Responsible sourcing
Policy
Responsible Sourcing
Anti-Bribery and Corruption
Code of Ethics
EDI
ESGS
Gift and Entertainment
Health and Safety
Modern Slavery and Human Trafficking
Compliance Statement
Action
5 year procurement plan
Target
Assessment of T1 High spend by 2027