Modern Slavery and Human Trafficking Statement 2021/2022

Introduction and Organisational Structure

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 (“the Act”) and sets out the steps that we, Speciality Drinks Group Limited (“the Company”) and our affiliates (The Whisky Experience Ltd, Whisky Auction Limited, and ABV Global Limited) (the “Group”) have taken and are taking to ensure that slavery and human trafficking is not taking place in our supply chain, or in any part of our business. The Group is a UK based, national and international drinks wholesaler and retailer, with over 20 years’ experience of selling to UK and international markets and is owned by The Whisky Exchange Holdings Limited.

Our Commitment

As part of the drinks industry, the Group recognises that it has a responsibility to take a robust, zero tolerance approach to slavery and human trafficking. We are committed to acting ethically, with integrity in all our business relationships, and to implementing, and enforcing, effective systems and controls to ensure slavery and human trafficking are not taking place anywhere within our Group and our supply chain.

Due Diligence, Risk Assessment and Management

The Group:

• is committed to supplying high-quality products that are sourced and manufactured in a fair, ethical and environmentally-responsible way;
• has a zero-tolerance approach towards modern slavery and human trafficking within its operations and supply chain;
• encourages its staff and those it works with to report any concerns they may have, in order to enable its management to act promptly on any concerns;
• conducts due diligence on suppliers;
• continues to review its supplier contract terms to identify compliance opportunities;
• continues to review and develop its Code of Business Conduct to ensure it supports our ethical standards and obligations under the Modern Slavery Act 2015;
• is committed to paying staff the national minimum wage;
• reviews, on a regular basis, all aspects of the supply chain, based on the supply chain mapping;
• adopts a stringent set of protocols if supplier failings are uncovered, this includes the use of sanctions against suppliers that fail to improve their performance in line with an action plan, or in a worst-case scenario, this may lead to the termination of the business relationship;
• maintains the appropriate registrations in the UK for its business activities, regularly conducting independent audits of its suppliers to ensure they are also fulfilling their regulatory responsibilities; and
• ensures that bespoke contracts continue to include compliance clauses.

Relevant Policies

The following policies outline the Group’s approach to the identification of modern slavery risks, and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing Policy: The Group encourages its staff, customers and other business partners to report any concerns related to both the direct activities and supply chains of the Group. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Group's whistleblowing procedure is designed to make it easy for staff to make disclosures, without fear of retaliation.
• Employee Handbook: The Group’s induction programme makes clear to staff the actions and behaviour expected of them when representing the Group. The Group strives to maintain the highest standards of employee conduct and ethical behaviour when operating within the UK and internationally.
• Recruitment Agency Policy: The Group uses only specified, reputable employment agencies to source from the labour market, and always verifies the practices of any new agency prior to working with them. We conduct robust checks on any new employee, including eligibility to work in the UK, to safeguard against human trafficking or individuals being forced to work against their will.

Key Performance Indicators (KPIs)

We will continue to monitor the effectiveness of our compliance regime and take necessary steps to address any identified instances of slavery and human trafficking and to ensure that breaches of the Group’s Anti-Slavery Policy are reported.

Training

Training on Group’s Anti-Slavery Policy and the risks of modern slavery and human trafficking in our business and in our supply chains is available to staff.

Approval of Statement

This statement has been approved by the Company’s Directors for the financial year ending 30th June 2025. This statement will be reviewed on an annual basis and will be updated if necessary.