Modern Slavery and Human Trafficking Statement

Black & White Group has zero tolerance for slavery, servitude, forced or compulsory labour, human trafficking, child labour, unlawful recruitment fees and other forms of exploitation.

Each Participating Business remains legally responsible for its own operations and supply chain. It must comply with applicable employment, right-to-work, agency-worker, safeguarding and modern-slavery requirements.

Suppliers and subcontractors must:

1. provide work freely entered into and permit workers to leave in accordance with law;
2. never retain passports or identity documents unlawfully;
3. never charge prohibited recruitment fees;
4. provide lawful pay, hours, rest and working conditions;
5. verify eligibility to work where required;
6. prevent intimidation, abuse and debt bondage;
7. maintain accurate employment and payment records; and
8. report suspected exploitation promptly.

Participating Businesses apply proportionate, risk-based checks when appointing and reviewing suppliers. Higher-risk work, labour models, locations or warning signs require enhanced enquiries, contractual controls, evidence or site-level verification.

Concerns should be reported through the relevant Participating Business or, where there is immediate danger, to the emergency services or appropriate authority. A business receiving a concern protects potential victims, preserves evidence, avoids actions that increase harm and seeks competent assistance.

A substantiated breach may result in corrective action, suspension, termination and referral to the authorities. Where harm is identified, the response prioritises the safety and rights of affected people.

Risk assessment considers labour intensity, temporary or migrant labour, recruitment intermediaries, low-margin subcontracting, high-risk goods or countries, opaque ownership, excessive working hours, accommodation dependence and weak worker voice. Indicators can include retention of identity papers, recruitment debt, unexplained deductions, restricted movement, threats, controlled wages, inconsistent accounts or inability to speak privately.

Supplier onboarding communicates the prohibition of forced, bonded, trafficked and child labour and the expectation of lawful wages, hours, recruitment and grievance routes. Higher-risk suppliers may be asked for labour-source information, policies, contractual flow-down, worker evidence or corrective action. Audit alone is not assumed to prove absence of exploitation.

Where a concern arises, immediate safety and victim welfare take priority. The business avoids abrupt action that could increase harm, preserves confidentiality and evidence, and seeks competent support or reports to the police, Modern Slavery and Exploitation Helpline, Gangmasters and Labour Abuse Authority or another appropriate body according to the circumstances. Commercial remedies are coordinated with victim-centred action.

Future reporting distinguishes activities completed from plans. Potential measures include people trained, suppliers assessed, high-risk reviews, concerns, response and corrective-action completion. Zero reports are not presented as conclusive proof that no exploitation exists.

During this statement period, Participating Businesses will continue to embed supplier expectations, proportionate due diligence, awareness and reporting arrangements. Future statements will describe material developments and verified performance where reliable evidence is available.

Approved by David Swaddle, Founder, on 31 August 2026.