PHILIP PAYNE LIMITED

Policies described

Freedom of workers to terminate employment Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits compulsory overtime Prohibits child labour Prohibits discrimination

Training described

Your whole organisation Your front line staff Human resources Executive-level staff Procurement staff Your suppliers

Worker engagement and working conditions

Your suppliers Trade unions or worker representative groups Professional auditors Workers within your organisation Workers within your supply chain

Social audits

Audit conducted by your staff Third party audit arranged by your organisation Audit conducted by your supplier’s staff

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app Through trade unions or other worker representative groups

Other monitoring

All suppliers have to comply with our Supplier Code of conduct and suppliers that were deemed high risk were visited and audited

Demonstrated progress

We measure how effective we have been by monitoring and recording (i) the number of employees specifically trained in the Modern Slavery Act and (ii) the number of suppliers, identified as being at increased risk of modern slavery, confirming that their organisations are slavery and human trafficking free. In FY26 our plan is to focus on organisations operating in countries having a higher risk of slavery and to ensure all our group companies understand our zero tolerance policy to slavery.

Reported risks and mitigations

• Risk: Sub tier components being manufactured in one of the 32 countries identified as human rights priorities on the UK government website
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Group: Women Migrants Refugees Children
• Location: China
• Mitigation: On site audits carried out by FW Thorpe Plc employees
• Risk: Temporary workers manufacturing our products in UK factories
• Area: Within your own operations
• Group: Women Migrants
• Location: United Kingdom
• Mitigation: We have reviewed our own internal recruitment policies and those of our key temporary worker agencies to ensure that our processes are robust and have the capability to identify and query any suspicious activities. We continually review external media reports, fines or sanctions against organisations where slavery incidents have occurred. We promote openness and transparency and provide avenues to all our employees and those working on our behalf to raise concerns.
• Risk: Temporary workers manufacturing products in our European factories
• Location: Germany Spain Netherlands
• Mitigation: We work with all our group companies to ensure they understand our zero tolerance policy on slavery and human trafficking within our operations or in the supply chain. We explain our expectations of behaviour and compliance with all applicable slavery acts and regulations. We provide guidance and training materials to these operations so they can give their employees a greater awareness of modern slavery. We promote openness and provide avenues for employees to raise concerns.