Anti Slavery Policy

Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

C G Fry & Son Ltd have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of an employees contract of employment and it may be amended it at any time.

Responsibility of the Policy

The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The Finance Director, as HR Lead, has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

Compliance with the Policy

All persons working for C G Fry & Son Ltd must ensure that they read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify yourlinemanager or a company directorassoon aspossible ifyou believe or suspect that a conflict with this policy has occurred, or may occurin the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of ourbusiness orsupply chains of any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your line manager or company Director OR report it in accordance with our Whistleblowing Policy as soon as possible.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your line manager or company Director.

We aim to encourage 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 any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook.

Communication and Awareness of this Policy

This policy will be communicated to all C G Fry & Son Ltd employees.

Our zero-tolerance approach to modern slavery will also be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

Breaches of this Policy

Any breach of this policy may constitute a disciplinary offence. Depending on the seriousness of any breach, disciplinary action may include summary dismissal.

Policy Review

The Board will ensure that this Policy is implemented, maintained and reviewed on a regular basis to reflect good practice and changes in legislation.

Signed on behalf of C G Fry & Son Ltd

LUDOVIC BLACKBURN

FCA FINANCE DIRECTOR

Date: 30th January 2018. Review by 31st January 2019.