MODERN SLAVERY ACT 2015 STATEMENT

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MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

This statement is published on behalf of Fuller, Smith & Turner P.L.C. and the other subsidiary companies within the Fuller, Smith & Turner P.L.C. Group (together “Fuller’s”) pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”).

This statement constitutes Fuller’s Modern Slavery and Human Trafficking Statement for the financial year ended 30 March 2024.  As required by the Act, this statement reports on the steps taken by Fuller’s during the year to prevent slavery and human trafficking taking place in any part of our own business or any of our supply chains.

Our structure and our business

Fuller’s is a premium pubs and hotels business founded in Chiswick, London in 1845 and listed on the premium market of the London Stock Exchange. Fuller’s has 185 managed businesses, with 1,025 boutique bedrooms, and 154 Tenanted Inns. The Fuller’s pub estate stretches from Brighton to Birmingham and from Bristol to the Greenwich Peninsula. Our Managed Pubs and Hotels include Cotswold Inns & Hotels – seven stunning hotels in the Cotswolds, Bel & The Dragon – six exquisite modern English inns located in the Home Counties and Lovely Pubs - seven beautiful village inns in Warwickshire. Further information can be found in our 2024 Annual Report, which is available on our website www.fullers.co.uk.

Modern slavery and human trafficking

We are committed to conducting our business ethically and with integrity, and striving to ensure that there is no modern slavery or human trafficking in any part of our business or supply chains.

Our supply chains

Our supply chains include the sourcing of raw materials and finished products for the purposes of providing food and drink, goods and equipment to be used in our pubs and hotels and our support office, construction and maintenance services for our freehold estate, contactors, sub-contractors, and professional service suppliers.  We have over 1,000 suppliers ranging in size and complexity, with the majority based in the United Kingdom.  In most cases we aim to develop long term relationships with our key suppliers and to rationalise the number of suppliers we partner with, but we do have a large number of smaller contractors who service the day-to-day requirements across our estate. We seek to maintain open communication with our contractors and suppliers regarding our values and expectations.

Prevention of modern slavery and human trafficking

We have policies and procedures in place to reduce the risk of modern slavery in our business, to ensure employees are protected and to promote human rights including:

Right to Work Policy: outlines procedures and responsibilities to ensure Fuller’s complies with all UK employment law and ensures our employees are fully entitled to work in the UK.

Whistleblowing Policy: outlines the procedure for raising concerns regarding suspected wrongdoing by Fuller’s or any of its employees or suppliers, including in confidence through an independent whistleblowing hotline.

Life is too good to waste programme: outlines our commitment to our people, our environment and our communities and includes initiatives to partner with our suppliers on key issues and to support our employees.

Due diligence processes for slavery and human trafficking in our supply chains

As part of our initiatives to identify and mitigate risk we:

·         identify and assess potential risk areas in our supply chains by asking all new key suppliers to provide details of their modern slavery arrangements as part of onboarding;

·         we do not engage any new key supplier of goods or services who does not align to our values and does not meet the standards we expect of them;

·         we comply with all aspects of UK employment law to mitigate the risk of people in our business being subject to any form of exploitation;

·         we have appointed a partner to undertake right to work checks to improve and streamline our onboarding checks;

·         we expect all agencies who supply workers for our pubs, hotels and Support Centre to comply with UK employment law; and

·         we have procedures in place to allow colleagues to report any wrongdoing whilst offering protection for whistle blowers, including an independent third-party helpline.

Progress

During the year we have:

·         commenced a programme of review meetings with food processing suppliers which includes discussion about their commitment to human rights and how they mitigate the risk of modern slavery;

·         initiated a review of our cleaning suppliers which we have identified as potentially being at higher risk of modern slavery and requiring further focus;

·         sourced a new online learning module which team members will be required to complete to help them spot the warning signs of modern slavery and how they should raise any concerns;

·         formalised a Risk Working Group that has cross department membership which, among other things, will help drive the launch of a revised Supplier Code of Conduct; and

·         continued to build our contract management depositary to ensure that a structured system is in place to track our suppliers’ modern slavery policies and practices.

Next Steps

Fuller’s remains committed to building and strengthening our existing policies and practices to further mitigate the risk of modern slavery and human rights violations across our business and in our supply chain. We therefore aim to continue to review the effectiveness of our current arrangements and, where necessary, implement additional safeguards and procedures. This will include:

·         rolling out the new online learning module to General Managers and Hotel team members and developing training for information to be cascaded to other team members;

·         reviewing our supplier minimum standards and launching the Supplier Code of Conduct which will set out our expectations of our suppliers;

·         ensure annual audit and certification checks continue to be conducted with our key suppliers to verify, among other things, their continued commitment to minimising the risk of modern slavery, including in their supply chain;

·         continuing to hold regular review meetings with food processing suppliers and extending the programme of review meetings to other key suppliers;

·         conclude the risk assessment of our cleaning suppliers to assess the measures they have in place to protect human rights and mitigate modern slavery;

·         continuing to explore possible partnerships with third-party experts to help target our mitigation and due diligence efforts; and

·         continuing to review the use of specialised ESG platforms, to allow us to manage our data more easily within our supply chain and to better manage sustainable sourcing, ESG and modern slavery risks across our supply chain.

This statement has been approved by the Board of Directors on 30 September 2024.

 

Simon Emeny, Chief Executive on behalf of

Fuller, Smith & Turner P.L.C.

Griffin Catering Services Limited

30 September 2024