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Modern Slavery Policy and Procedure

MODERN SLAVERY POLICY AND PROCEDURE

1 Introduction

1.1 This Modern Slavery Policy and Procedure is discretionary in nature. Whilst the George Browns Group expects compliance with this policy, it doesn’t confer contractual rights or form employment contracts. Moreover, the policy may be amended by the George Browns Group or replaced at any time following appropriate consultation with recognized trade unions.

1.2 Breach of this policy may be addressed via the George Browns Group’s disciplinary and code of conduct policies.

1.3 This policy and procedure will be reviewed on a 3-year basis or amended in response to changes in future legislation and/or case law.

1.4 Modern Slavery includes slavery, servitude, forced and compulsory labour, and human trafficking. These practices deprive a person of their liberty in order to exploit them for personal or commercial gain.

2 Ownership and review

The directors of GEORGE BROWN’S IMPLEMENTS (HOLDINGS) LIMITED review and signoff the Modern Slavery statement annually.

3 Organisational Scope

This Modern Slavery Policy and Procedure is a corporate policy that applies to all employees (and workers, as applicable) of The George Browns Group. This includes any wholly owned subsidiaries. It applies unless an alternative policy exists, subject to any qualifying conditions.

4 Definitions

4.1 The ‘George Browns Group’ refers to the following companies; GEORGE BROWN’S IMPLEMENTS (HOLDINGS) LIMITED Company number 00926412 , GEORGE BROWNS LIMITED Company number 00340609, BROWN’S AGRICULTURAL MACHINERY COMPANY LIMITED Company number 00720517,  G.B.I. FARMS LIMITED Company number 02239230.

4.2 Modern Slavery includes slavery, servitude, forced and compulsory labour, and human trafficking. These practices deprive a person of their liberty in order to exploit them for personal or commercial gain.

5 Policy Statement

5.1 Under the Modern Slavery Act 2015 modern slavery is a criminal offence. The George Browns Group is committed to ensuring that modern slavery is not taking place anywhere within our own business. Furthermore, this commitment extends to all levels of our supply chains.

5.2 The George Browns Group is committed to ensuring transparency in our approach to tackling modern slavery. We also commit to complying with disclosure obligations under the Modern Slavery Act 2015.

5.3 In employment of our own employees we prohibit modern slavery or the hiring of individuals that are under 16 years of age. We fully comply with legislation applicable to the hiring and protection of employees within the workplace and compensation for work undertaken. This includes Health and Safety legislation and minimum wage requirements. The George Browns Group does not consider there is a risk of modern slavery being present in its directly employed workforce however we will regularly review our policies and practices.

5.4 The George Browns Group expects all suppliers, contractors, and business partners to observe the same high standards. We will include specific prohibitions in our contracts against the use of forced, compulsory, or trafficked labour, as well as any held in slavery or servitude. We will communicate our approach to all suppliers, contractors and business partners at the outset of our business relationship (see section 7 Procurement).

6 Key Principles

6.1 The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all employees. Additionally, this responsibility also extends to suppliers or business partners over which we exercise control.

6.2 All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

6.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy. Moreover, managers must identify areas needing extra modern slavery training, especially for those managing partnerships.

6.4 All employees must read, understand and comply with this policy.

6.5 The George Browns Group encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers detrimental treatment for reporting suspicions of modern slavery. This applies internally. Furthermore, this commitment also extends to any suspicions regarding modern slavery within any of our supply chains. Employees should inform their line manager or HR immediately if they believe they’ve suffered detrimental treatment, following the Grievance Policy.

6.6 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, will be provided as necessary following needs analysis.

7 Procedure

7.1 Employees are encouraged to report any suspicion of modern slavery within our business or supply chains. Additionally, they should do so at the earliest possible stage.

7.2 Any employee who believes or suspects a breach of this policy or the Modern Slavery Act 2015 has occurred must notify their line manager. This includes situations where a breach may occur in the future. The relevant group manager or HR Department as soon as possible. Alternatively, concerns can be raised using the George Browns Group’s Whistleblowing Policy and Procedure.

7.3 Employees unsure about whether an act constitutes modern slavery can discuss with their line manager. This applies to any tier of our supply chains. Additionally, they can also consult with the Head of Procurement & Commercial Services or the HR Department.

7.4 Any employee who breaches this policy or the Modern Slavery Act 2015, subject to investigation, may face disciplinary action. Furthermore, such action could result in dismissal for misconduct or gross misconduct.

7.5 Steve Brown, Holdings Director, is nominated to ensure external supply chain compliance with this policy.

7.6 Through self-assessment, key suppliers are required to confirm agreement and compliance with this policy.

7.7 Steve Brown Holdings director will, at his or her discretion, implement appropriate audits of any key supplier to identify potential risk.

7.8 The George Browns Group may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy. Eventually, termination may occur if they fail to allow the Head of Procurement & Commercial Services appropriate audit/assessment access.

8 Reporting

The George Browns Group will provide an annual statement in compliance with the Modern Slavery Act 2015, following each financial year. The statement will be published on the George Browns Group website.

Please ensure you fill out the Modern Slavery Self-assessment form

For our general Terms and Condition