Slavery and Human trafficking

Introduction

The Modern Slavery Act 2015 (“the Act”) requires all commercial organisations carrying on business in the UK with turnovers in excess of £36m to publish a Slavery & Human Trafficking Statement.

The Act is aimed at combating two criminal offences collectively referred to as “modern slavery”:

• Slavery, servitude and forced or compulsory labour; and
• Human trafficking.

One of the key focus points of the legislation is for organisations to “shine a light” through their supply chains so that any illegal practices are discovered and tackled. Organisations are therefore required to analyse all elements of their supply chain including their major suppliers as well as their incidental/minor suppliers, even those deemed to be low risk.

S.A. Brain Group

This Slavery & Human Trafficking Statement applies to S.A. Brain & Co Limited (Co No 52099) and all of its subsidiary companies, referred to as the “Company”. The Company’s main business areas include:

• Licensed property ownership
• Pub and hotel retailing (Managed Houses)
• Licensed property leasing (Tenanted Houses)
• Brewing and packaging beer
• Beer, cider, wines, spirits and minerals wholesaling

Anti-Slavery Policy

The Company is committed to upholding human rights. It is totally opposed to slavery and human trafficking in its direct operations, its indirect operations and its supply chain as a whole. The Company has taken, and will continue to take, steps to ensure that slavery and human trafficking does not take place in any part of the business or its supply chains.

Supply Chain

As a brewer, pub owner and operator we purchase goods and services from a variety of suppliers including raw materials, food and beverage products, maintenance and building contract services, distribution services, fixture and fittings, consulting services, among others.

Due Diligence

The Company completes due diligence on its suppliers, where practicable, to satisfy itself that it is trading with a reputable organisation. The Company expects all those in its supply chain to be opposed to slavery and human trafficking.

As a minimum, the Company expects each entity in its supply chain to adopt ‘one-up’ due diligence on the next link in the chain for those organisations governed by the Act. It is not practical for the Company to have a direct relationship with all links in the supply chain.

The Company has a system in place to encourage the reporting of concerns and the protection of whistleblowers.

Training

The Directors of the Company have approved this Statement and it is available on the S.A. Brain & Co Limited website.

Statement Review

This Statement will be reviewed on an annual basis and will be updated if required.

Charles Brain, Company Secretary

February 2020