Managing our approach

We are a responsible business and comply with all legal requirements of the countries where we operate. Responsible conduct is a critical element of our corporate culture and embedded in our strategy. We always operate with the highest degree of integrity and ethics.

Our responsibilities

It is our responsibility to conduct our business ethically, making consideration for our ESGS purpose and being a good employer, as we grow and succeed together. We have a strong governance structure in place.
The Modulaire executive team and Board of Directors take our commitments seriously and seek to deliver our strategy and targets in a way that our employees, customers, shareholders and suppliers can be proud of.

Delivering on 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 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.

In line with best practice, we update our ESGS-related policies and documentation, or generate new documentation, on an ongoing basis to ensure compliance and for continuous improvement. In 2023, we created or updated the following policies to align with new strategy and frameworks:

  • Responsible Sourcing Policy;
  • Policy on Sustainable Use of Water; and
  • Policy on Waste Management.

Governance structure for ESGS

Board of Directors (including independent)

Provides ESGS oversight and approves material ESGS initiatives, disclosures and reports.

Environment, Social, Governance and Sustainability (ESGS) CommitteeBrookfield-nominated member, Group CEO, Group General Counsel, ESGS Director, Chief Human Resources Officer

Responsible for assisting the Board in articulating and developing our ESGS strategy, mission and tactics. It meets twice a year to provide oversight of sustainability initiatives, in line with our purpose, values and strategy. This includes monitoring, disclosures and other reporting on ESGS matters.

Executive CommitteeSenior Management Team, Managing Director from each SBU

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 / ForumESGS Managers from each SBU and leads from relevant functions in SBUs (e.g. Operations, HR, Finance)

Responsible for executing ESGS mandate and initiatives outlined by the ESGS Committee.

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Respecting Human Rights

Our commitments

Modulaire is committed to protecting human rights across our operations and supply chain, including for our employees, on-site contractors, suppliers, customers and consumersand in the communities around our operations. 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 (Social purpose and actions). Read our Modern Slavery and Human Trafficking Compliance Statement here:

Assessing our risks

Our double materiality process is outlined in this report and has raised salient human rights issues, which are addressed through our ESGS strategy (see page 18 of the report, ref: S1-S5, G1-G5).

Our modern slavery risk assessment considers the three key modern slavery risk factors of vulnerable populations; high-risk sectors; and high-risk geographies.

Based on the risk factors we have identified, there are varying levels of modern slavery risk exposure across our business:

Our suppliers: we can potentially be exposed to modern slavery risk if it is present in our supply chain. For example, 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.

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.

Customers: there may be a risk of exposure to modern slavery through the leasing services, for example, units provided to clients operating in sectors with base-skill labour and long complex supply chains (such as construction sectors) can present a higher risk of exposure to modern slavery.

Risk mitigation

Where risk is identified during our ESGS due diligence assessment, our people will identify lessons or opportunities for improvements to be shared with our Procurement team, ESGS Committee and the Board as necessary. Where issues are identified during our due diligence process, we will agree corrective actions between the relevant parties, documenting the process and outcomes.

Supplier Code of Conduct

The Supplier Code of Conduct reflects our 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, with 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

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
  • 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

Continuous improvement and measurement

We are committed to continuously improve our supplier governance framework and process controls. This year, Algeco UK received a score of 90% on the Modern Slavery Statement and Modern Slavery Assessment Tool, a 32% increase from 2022, and achieving the UK Government's green category for public sector organisation suppliers.

Elisha McAuliffe Murphy

Our Responsible Sourcing process brings people together. Across suppliers and our internal teams, it’s all about collaboration.

Elisha McAuliffe Murphy

Senior Legal Counsel

Demonstrating responsible governance

At Modulaire Group, we are committed to doing business in the right way to maintain trust and respect. We continue raising awareness of ESGS with our people and our suppliers to increase the level of understanding around our commitments, strategy and disclosure frameworks.

Sourcing responsibly

We depend on our suppliers, and the goods they produce, to make our own. To understand more about the ESG impacts of our suppliers, we have introduced the Modulaire Group ESGS Responsible Sourcing Policy. The purpose is to:

  • ensure collaboration with suppliers;
  • embed ESGS at all stages;
  • review ESGS performance;
  • drive continuous ESGS improvement;
  • and to provide a safe, inclusive, diverse and motivating
  • environment across our value chain
  • We have also implemented a Responsible Sourcing screening process to help us conduct due diligence for new and existing suppliers.

Modern Slavery Assessment standards

Algeco UK achieved a score of 90%, a significant increase of 32% from 2022 on the Modern Slavery Statement and MSAT (Modern Slavery Assessment Tool), achieving the UK Government’s green category for public sector organisations' suppliers.

Effective performance management

Modulaire adopts external ESGS best practice standards and certification, where they will help us maintain or improve effective performance management. ISO 14001 is an internationally agreed standard, which supports the continuous improvement of environmental performance through resource efficiency and waste reduction. This year, we achieved ISO 14001 certification at all of our design and assembly facilities and are now seeking to achieve coverage at all sites (currently at 56%).


Our Group has completed 458 hours of Cybersecurity training for all computer users, which is ongoing with other initiatives underway. We have also completed 1,373 training hours on Code of Ethics, including anti-bribery and anti-corruption training.

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 moreabout our priorities, activities and best practice.


Ahead of the upcoming EU Corporate Sustainability Reporting Directive (CSRD), we have completed a gap analysis and developed a double materiality analysis.

Sustainability ratings

Algeco France, Belgium and the UK have achieved a gold rating in Sustainability from EcoVadis. The evaluation involves a review of ESG performance in four key areas: Environment, Ethics, Labour & Human Rights, and Sustainable Procurement. A gold rating is the second highest grade an organisation can achieve and means EcoVadis has rated them in the top 5% of 100,000+ companies in 175+ countries and 200+ industries, with Algeco Germany also achieving the Silver Medal.

Progress on our Governance KPIs

We have achieved all three of our Governance 2023 KPIs.

KPI Progress Status
Screen for ESGS criteria in new and renewed supplier contracts Achieved Achieved
All design and assembly facilities to achieve ISO 14001 Achieved Achieved
Progress Cybersecurity training Achieved Achieved
AchievedAchieved OngoingOngoing Not achievedNot achieved