MODERN SLAVERY POLICY

Modern Slavery Policy Statement Snapshot
• This statement sets out St Austell Brewery Family Group’s actions aimed at ensuring that there is no slavery or human trafficking in its own business or its supply chain.
• This statement is reviewed each year and will set out the actions and activities during the previous 12 months and our plans for the coming year to combat modern slavery.

Introduction
St Austell Brewery Company Limited is committed to conducting business responsibly and we have a zero-tolerance approach to all forms of modern slavery and human trafficking across our operations and supply chain. This statement, published in accordance with the Modern Slavery Act 2015, sets out the steps that we have taken over the last year to detect and prevent modern slavery in our business and supply chains. It also details what we will be implementing in the coming year to continue to combat modern slavery and human trafficking.

Company Structure
St Austell Brewery Ltd is an independent family-owned business. The company has three separate business areas. Pubs, Inns & Hotels, Beers & Brands and Group Support. We are based primarily in the Southwest of England and our head office is in St Austell, Cornwall.

Supply Chains
Our supply chain is in excess of 3,000 suppliers. 1,400 of which have been used in the last 12 months, covering food and drink suppliers for our pubs, raw materials for our beers, as well as goods and services not for resale such as equipment used in our pubs, point of sale materials, IT equipment, utilities and waste services, contractors engaged in building and maintenance, marketing, advertising, recruitment and training and a wide range of other professional services. 1816 of our active suppliers have signed to say that they adhere to the Modern Slavery Act 2015. 850 of these suppliers have also agreed to our anti- slavery policy via our online portal.

Policy on slavery and human trafficking
We do not tolerate acts of slavery and human trafficking in any form, across our business and in our supply chains. We are committed to seeking out and preventing all acts of slavery and human trafficking in our business and supply chain.

Due diligence and risk management
As part of our commitment to combating modern slavery and human trafficking we have identified areas in our business and supply chain that are more at risk of being areas that modern slavery and human trafficking could occur.
Across our business we have a number of policies and procedures in place to mitigate these risks: -
• In the last year we have introduced a new applicant tracking system which will not let staff be on-boarded/put on the rota until we have approved their right to work documentation.
• We have also partnered with an independent company to verify all right to work documents that are supplied to us.
• We perform regular reviews of relevant documentation to ensure all staff are eligible to work in the UK.
• We perform regular reviews to ensure all staff are being paid on or above the National Minimum Wage.
• Unless new suppliers agree to our terms and conditions and confirm that they are compliant with the anti-slavery act then we will not agree to work with them.
• All staff complete mandatory training when they join the Company which provides knowledge of their legal responsibilities to protect themselves and those they work with.
• We maintain a whistleblowing policy to encourage members of staff to report concerns about wrongdoing and which offers suitable protection for whistle-blowers.
• We subject relevant processes and procedures to periodic internal audit, to verify these are operating effectively.

Effective actions to address modern slavery
Over the coming 12 months we intend to implement the following changes to further prevent modern slavery and human trafficking
• Abolish the use of zero-hours contracts across our entire business.
• Ensure that all new suppliers are aware of our zero-tolerance stance and what we expect from them in this regard.
• Provide training around spotting modern slavery and human trafficking to relevant employees in our business.
• Our finance team are now actively reaching out to pre-existing suppliers to ask them to visit the portal and submit their anti- slavery status. Ensuring that all the suppliers that we have worked alongside for many years and whom pre-date our online portal, also are communicated with and agree to our current T&Cs/anti- slavery.

Approval
Our board of directors, which has agreed to champion the understanding and implementation of this statement, will be regularly briefed on the actions we have taken. This statement is made in accordance with Section 54(1) of the Act and constitutes our slavery and human trafficking statement for the financial year 2021 to 2022 It was approved by our board of directors on 01/12/21 and signed on its behalf by Kevin Georgel – Chief Executive Officer.

Kevin Georgel
Chief Executive Officer