OUR MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Brookbourne Holdings Limited – Modern Slavery and Human Trafficking Statement

Introduction

This statement sets out the actions that Brookbourne Holdings Limited (“the Company ”) undertake, to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the year 1st January to 31st December 2024.

Operating in the consulting and wholesale business, the Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The Company has a zero-tolerance approach to slavery, trafficking or forced labour in any part of our business and ensures that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

As an established operator with an unrivalled network of professional partners across the world. We are experts in all major Global trade markets and specialists in Europe, Middle East, China, Africa and South East Asia.

Employees at Company locations fall into the category of office staff. The Company also uses consultants and external advisors, as the need arises. As we operate in the Isle of Man, the UK and around the world, whilst we might handle products imported or exported by our customers, there is little scope for any direct activities to be exposed to slavery or human trafficking.

The following is the process by which the Company assesses whether particular activities or countries are high risk in relation to slavery or human trafficking.

Responsibility

Responsibility for anti-slavery initiatives is as follows:

Policies: The Human Resources Department are responsible for putting in place and reviewing policies and the process by which they were developed.

Risk assessments: The Health & Safety Department are responsible for human rights and modern slavery risk analysis.

Investigations/due diligence: The Human Resources Department are responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking and explain their specific role.

The Company operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations, all of which are accessible to all staff via the intranet:

Whistleblowing Policy – The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

Anti-slavery and Human Trafficking Policy – The Company is committed to ensuring there is transparency in our organisation and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

Child Labour Policy – The Company is committed to the principles of protecting children from child labour exploitation. The Company believes that their future development and that of the communities and countries in which they live is best served through education not child labour.

Dignity at Work Policy – The Company makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour.

Recruitment Policy – The Company and its associated companies uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due diligence and Supply Chain

The Company and its associated companies are committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.

The Company ensures that all Overseas Partners (3rd party suppliers) who operate on behalf of the Company abide by the laws and relevant legislations. The Company regularly reviews the agreements to ensure they remain compliant.

The Company undertakes due diligence when considering taking on new contracts and annually reviews its existing contracts.

Performance indicators

The Company reviews its key performance indicators (KPIs) to ensure that they are improving or to detect any issues that need to be addressed. As a result, the Company has taken steps to ensure that there are no breaches of Modern Slavery or Human Trafficking within the Company , and its 3rd party suppliers. To date, there is no indication from employees, the public or Law enforcements agencies that Modern Slavery or Human Trafficking is present within the Company , its associated companies or suppliers.

Awareness-raising programme

To ensure that the employees understand the basic principles of the relevant legislation and ensure that the Company is 100% compliant, it will continue to ensure that it and its 3rd party suppliers are compliant, and that no Modern Slavery or Human Trafficking is taking place. The Company will raise awareness of modern slavery through regular reminders and by adding this statement to the Company internet site.

The organisation’s methods of raising awareness of slavery awareness include;

- how to identify the signs of slavery and human trafficking;

- what initial steps should be taken if slavery or human trafficking is suspected;

- how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;

- what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; 

- The Company publishes all policies and procedures on the Company internet page to ensure employees are aware of not just the Company responsibility, but their responsibility to raise any suspicions or evidence of potential slavery or human trafficking issues to the relevant parties within the organisation.

Board approval

This statement has been formally approved by the Board of Directors of Brookbourne Holdings Limited