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Legal & Compliance

Modern Slavery Statement

Effective Date: February 2026

1. Introduction

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015and constitutes Alcohol Ltd's modern slavery and human trafficking statement for the financial year ending 31 January 2026.

Alcohol Ltd (Company Number: 04854930) is committed to acting ethically and with integrity in all of our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our operations or supply chains.

2. Organisation Structure and Business

Alcohol Ltd is a UK-registered private limited company focused on lobbying, representing the interests of the UK alcohol sector. Our activities include:

  • Industry representation and advocacy before government, regulatory bodies, and Parliament;
  • Policy research and analysis on matters affecting the alcohol industry;
  • Stakeholder engagement and consultation facilitation;
  • Strategic communications and public affairs advisory services.

Our registered office is located in the United Kingdom. As a service-based organisation with a limited supply chain, our primary risk exposure to modern slavery relates to professional services, technology suppliers, and facilities management.

3. Our Commitment

Alcohol Ltd has zero tolerance for modern slavery and human trafficking. We are committed to:

  • Ensuring transparency throughout our organisation and with our suppliers of goods and services;
  • Acting ethically and with integrity in all business dealings and relationships;
  • Implementing and enforcing effective systems and controls to safeguard against modern slavery in our operations;
  • Not knowingly supporting or doing business with any organisation involved in slavery or human trafficking;
  • Taking a zero-tolerance approach to modern slavery and committing to act ethically in all circumstances.

4. Policies and Governance

Alcohol Ltd maintains robust policies that underpin our commitment to ethical conduct and the prevention of modern slavery:

4.1 Anti-Slavery and Human Trafficking Policy

We have implemented an internal Anti-Slavery and Human Trafficking Policy that sets out our approach to identifying and preventing modern slavery in our operations and supply chains. This policy is communicated to all employees, contractors, and relevant suppliers.

4.2 Recruitment and Employment Practices

All employment is conducted in accordance with UK employment law. We ensure that all employees have the right to work in the UK, are provided with written terms and conditions of employment, and are paid at least the National Living Wage. We do not withhold identity documents or require payment of recruitment fees from workers.

4.3 Whistleblowing and Reporting Mechanisms

We encourage all employees, contractors, and stakeholders to report any concerns relating to modern slavery without fear of retaliation. Our whistleblowing procedures provide confidential channels for raising concerns, which are investigated thoroughly and acted upon where appropriate.

4.4 Code of Conduct

Our Code of Conduct requires all those working for or with Alcohol Ltd to uphold high standards of ethics and integrity, including compliance with all applicable laws relating to modern slavery and human trafficking.

5. Supply Chain Due Diligence

Alcohol Ltd recognises that modern slavery risks exist within global supply chains. We are committed to understanding and mitigating these risks through the following due diligence measures:

5.1 Supplier Assessment

We conduct risk assessments of our suppliers, with particular attention to those operating in high-risk sectors or geographic regions. We evaluate suppliers' own policies and practices regarding modern slavery and human trafficking.

5.2 Contractual Requirements

Our contracts with suppliers include specific provisions requiring compliance with the Modern Slavery Act 2015 and permitting us to terminate relationships if any indication of modern slavery is identified. Suppliers are required to confirm their compliance with anti-slavery legislation.

5.3 Ongoing Monitoring

We maintain ongoing relationships with our suppliers and conduct periodic reviews to ensure continued compliance. Where concerns arise, we engage with suppliers to address issues and, if necessary, terminate business relationships.

6. Risk Assessment

Alcohol Ltd conducts an annual risk assessment to identify potential areas of exposure to modern slavery risks within our operations and supply chains. Our assessment considers:

  • Geographic Risk: Suppliers operating in jurisdictions with weak labour protections or high incidence of forced labour;
  • Sector Risk: Industries known to have higher prevalence of modern slavery, such as cleaning services, hospitality, construction, and technology manufacturing;
  • Operational Risk: Use of labour provided through third-party agencies or subcontracting arrangements;
  • Vulnerability Indicators: Poor working conditions, excessive working hours, withholding of wages, or restrictions on freedom of movement.

Where elevated risks are identified, we implement enhanced due diligence measures and engage directly with suppliers to ensure compliance with our standards.

7. Training and Awareness

Alcohol Ltd is committed to building awareness of modern slavery issues among our employees and stakeholders. Our training initiatives include:

  • Induction Training: All new employees receive training on modern slavery awareness, recognising signs of exploitation, and reporting procedures;
  • Ongoing Training: Regular training updates are provided to staff, particularly those involved in procurement, human resources, and supplier management;
  • Senior Leadership Engagement: Our senior management team receives briefings on modern slavery risks and the organisation's obligations under the Modern Slavery Act 2015;
  • External Engagement: We stay informed of best practices and emerging risks through participation in industry forums and engagement with relevant organisations.

8. Measuring Effectiveness

To assess the effectiveness of our efforts to prevent modern slavery, Alcohol Ltd monitors the following key performance indicators:

  • Percentage of suppliers that have completed modern slavery compliance assessments;
  • Number of staff trained on modern slavery awareness;
  • Number of concerns reported through whistleblowing channels and actions taken;
  • Supplier compliance with contractual anti-slavery provisions;
  • Results of periodic supplier audits and risk reviews.

We review these indicators annually and adjust our policies and practices as necessary to strengthen our approach.

9. Reporting Concerns

⚠️ IMMEDIATE DANGER

If you or someone you know is in immediate risk of modern slavery or human trafficking, contact the police on 999 immediately. Do not delay reporting to us if there is an immediate threat to safety.

If you have concerns regarding potential modern slavery or human trafficking within Alcohol Ltd's operations or supply chains, we encourage you to report them to us through the following channels:

Email: compliance@alcohol.uk

Subject Line: Modern Slavery

Post:

Compliance Officer - Modern Slavery
Alcohol Ltd
The Limes
Bayshill Road
Cheltenham
GL50 3AW
United Kingdom

Mark envelope: "Confidential - Modern Slavery Report"

All reports will be treated with the utmost confidentiality and investigated thoroughly. We are committed to ensuring that no individual suffers any detrimental treatment as a result of reporting suspicions of modern slavery in good faith.

10. Continuous Improvement

Alcohol Ltd recognises that combating modern slavery requires ongoing vigilance and continuous improvement. We are committed to:

  • Regularly reviewing and updating our policies and procedures in light of emerging risks and best practices;
  • Engaging with industry peers, civil society organisations, and government bodies to share knowledge and strengthen collective action;
  • Enhancing transparency in our supply chains and encouraging our partners to adopt similar standards;
  • Allocating appropriate resources to ensure effective implementation of our anti-slavery measures.

11. Approval and Review

This statement has been approved by the Board of Directors of Alcohol Ltd and will be reviewed annually. We are committed to transparency and accountability in our efforts to prevent modern slavery and human trafficking.

Statement Date: February 2026

Financial Year Covered: 1 February 2025 - 31 January 2026

Next Review Date: February 2027

This statement is published in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Alcohol Ltd's slavery and human trafficking statement for the current financial year. We remain committed to ethical business practices and the eradication of modern slavery in all its forms.