D&F McCarthys

Policy Reference: MSP-001     Version: 1.0     Date Issued: March 2026     Review Date: March 2027

1. Introduction & Commitment

D&F McCarthys is committed to acting ethically and with integrity in all our business dealings and relationships. We operate a zero-tolerance approach to modern slavery and human trafficking in all its forms.

This policy reflects our commitment to acting in accordance with the Modern Slavery Act 2015 and sets out the steps we are taking to ensure that modern slavery and human trafficking are not taking place within our business or supply chains.

2. Scope

This policy applies to all persons working for or on behalf of D&F McCarthys, including:

•       All employees (full-time, part-time, and temporary)

•       Directors and senior management

•       Contractors, consultants, and agency workers

•       Suppliers, sub-contractors, and business partners

3. What Is Modern Slavery?

Modern slavery is a serious crime and a grave violation of fundamental human rights. It takes several forms, all of which deprive victims of their liberty in order to exploit them for personal or commercial gain. These include:

•       Slavery – owning or treating a person as property

•       Servitude – forcing someone to provide services under coercion

•       Forced or compulsory labour – work obtained by threats or violence

•       Human trafficking – recruitment, movement, or receipt of individuals through deception or coercion for exploitation

•       Child labour – the exploitation of children in any form of labour

4. Our Responsibilities

D&F McCarthys takes a proactive approach to identifying and mitigating risks. We will:

•       Ensure all staff are paid at least the National Living Wage and are free to leave their employment

•       Carry out appropriate due diligence on suppliers and contractors before engagement

•       Include anti-slavery clauses in contracts with suppliers and business partners

•       Regularly review and audit our supply chains to identify areas of risk

•       Provide training and awareness for relevant employees

•       Maintain clear and accessible reporting channels for concerns

5. Due Diligence & Supply Chain

We recognise that supply chains can represent an area of risk. D&F McCarthys will:

•       Map our supply chains to understand their nature and identify higher-risk areas

•       Require key suppliers to confirm their commitment to ethical trading and compliance with the Modern Slavery Act 2015

•       Take action to address any supplier who fails to meet our standards, up to and including termination of the business relationship

•       Prioritise suppliers who demonstrate a strong commitment to ethical employment practices

6. Risk Assessment

We assess the risk of modern slavery within our operations and supply chains on an ongoing basis. Higher-risk areas are subject to enhanced due diligence, including site visits, third-party audits, and worker interviews where appropriate.

Factors we consider in our risk assessment include: geographic location of suppliers, industry sector, nature of labour involved, and the vulnerability of the workforce.

7. Training & Awareness

We ensure that all employees who are responsible for procurement, HR, or supply chain management receive appropriate training on modern slavery, including how to identify warning signs and report concerns.

All new staff will receive information about this policy as part of their induction. Refresher training will be provided periodically.

8. Reporting Concerns

D&F McCarthys encourages all employees, contractors, and business partners to report any concerns relating to modern slavery or human trafficking. Concerns can be raised through the following channels:

•       Line Manager – in the first instance

•       HR Department – confidentially, in person or in writing

•       Senior Management – if concerns involve a line manager

•       Modern Slavery Helpline – 0800 0121 700 (confidential and free)

•       Crimestoppers – 0800 555 111 (anonymous)

All concerns will be taken seriously and investigated promptly. We will not tolerate any form of retaliation against anyone who raises a concern in good faith.

9. Breaches of This Policy

Any employee found to be in breach of this policy may face disciplinary action, up to and including dismissal. Any supplier or third party found to be involved in modern slavery or human trafficking will have their contract terminated immediately and will be reported to the relevant authorities.

10. Monitoring & Review

This policy will be reviewed annually by senior management, or sooner in the event of legislative changes or a material change in our business operations.

11. Responsibility for This Policy

Overall responsibility for this policy and its implementation lies with the Directors of D&F McCarthys. Day-to-day responsibility for ensuring compliance is delegated to senior management.