For the Financial Year 2025/2026

This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 and sets out the steps taken by Angus Dundee Distillers Plc to prevent modern slavery and human trafficking in our business operations and supply chains.

Angus Dundee Distillers Plc is committed to conducting business responsibly, ethically, and with respect for human rights. We have a zero-tolerance approach to modern slavery in any form.

1. Organisation Structure and Business

Angus Dundee Distillers Plc is a family-owned Scotch whisky producer established in 1988, with the family involved in the whisky industry for over 70 years.

Our operations include:

• Distilling
• Maturation
• Warehousing
• Bottling and blending
• Sales and distribution

Our main operational sites are located in Scotland, with a head office in London and sales divisions operating in overseas territories.

2. Policies in Relation to Modern Slavery

Angus Dundee Distillers Plc has implemented a comprehensive suite of policies that support our commitment to preventing modern slavery and protecting human rights. These include:

• Human Rights Policy (aligned to the ETI Base Code)
• Ethical Recruitment Policy
• Right to Work Policy and Procedure
• Equality & Non-Discrimination Policy
• Dignity at Work and Anti-Harassment Policies
• Grievance Procedure
• Whistleblowing Policy
• Business Ethics & Anti-Bribery Policy

These policies apply to employees, agency workers, contractors, and relevant business partners and are reviewed regularly.

3. Due Diligence Processes

We operate due diligence processes to identify and mitigate modern slavery risks within our operations and supply chain, including:

• Verification of right-to-work documentation for all employees and agency workers before work commences
• Ethical recruitment controls, including a prohibition on recruitment fees
• Use of approved labour providers, subject to contractual obligations and compliance checks
• Clear contractual expectations communicated to suppliers regarding labour standards and ethical conduct
• Internal procedures for raising concerns through grievance and whistleblowing channels

Where risks or concerns are identified, corrective actions are taken, and business relationships may be reviewed.

4. Risk Assessment and Management

Angus Dundee Distillers Plc recognises that modern slavery risks can arise in areas such as:

• Use of agency labour
• Packaging, logistics, and overseas supply chains

While the majority of our suppliers are long-established and UK or EU-based, we do not consider ourselves risk-free. We therefore take a risk-based approach, focusing due diligence efforts on areas where vulnerability may be higher.

We work collaboratively with suppliers to address risks and promote continuous improvement rather than disengagement wherever possible.

5. Effectiveness and Monitoring

We assess the effectiveness of our approach to preventing modern slavery through:

• Monitoring compliance with recruitment and right-to-work procedures
• Review of labour provider practices
• Management reviews
• Investigation of grievances or whistleblowing reports relating to labour practices
• To date, no confirmed incidents of modern slavery have been identified within our operations or supply chain. Monitoring and review remain ongoing.

 

6. Training and Awareness

Relevant employees, including those involved in recruitment, HR, procurement, and labour provider management, receive training on:

• Modern slavery awareness
• Ethical recruitment
• Human rights and labour standards

All employees are required to review and acknowledge the Company’s Policies and Procedures Manual, which consolidates key policies and reinforces expectations around ethical conduct and reporting concerns.

Approval

This statement has been approved by the Board of Directors of Angus Dundee Distillers Plc and is signed on its behalf.

Signed: Steven McNeil

Operations Director

Angus Dundee Distillers Plc

Date: 21/01/2026

Publication

This statement will be reviewed annually and is published on the Angus Dundee Distillers Plc website.