Modern Slavery Statement

This statement applies to W.R. Kennedy & Company.

ABOUT THIS STATEMENT

This is W.R. Kennedy & Company’s Modern Slavery Statement in accordance with section 54 of the Modern Slavery Act 2015 which applies for the financial year ending 31 March 2023, and was approved by the Board of Directors on 29^th September 2023.

W.R. Kennedy & Company is committed to the highest level of ethical standards and sound governance arrangements and ensuring that there is transparency in its own business and in its approach to tackling modern slavery throughout its business and supply chain and expects the same high standards from all of its contractors, suppliers and other business partners. We consider the measures highlighted within this statement, together with W.R. Kennedy & Company’s overall approach to ethics and employee and supplier engagement, are helping to reduce the risk of modern slavery and human trafficking in its business and supply chain.

ORGANISATIONAL STRUCTURE

With our head office based in Ballymena, Northern Ireland, W.R. Kennedy & Company is an unlimited liability company with it’s ownership and management all based in Northern Ireland

WR KENNEDY & COMPANY BUSINESS AND SUPPLY CHAIN

We have close relationships with our suppliers who are recognised as being socially responsible. We expect our suppliers to comply with all relevant standards and expect them to treat employees fairly and safely.

Further details on W.R. Kennedy & Company can be found at www.wrkennedy.com

POLICIES AND PROCEDURES

W.R. Kennedy & Company has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its own business or in any of its supply chains.

The Policy on Modern Slavery reflects the Company’s commitment to prevent modern slavery including the roles and responsibilities from the Board level down to each individual employee and the means by which any suspected incidences of modern slavery should be reported. Employees were briefed on the policy during the year.

Some of the other W.R. Kennedy & Company policies which are considered relevant to the management of modern slavery risks faced by the Company include:

Whistleblowing Policy – This Policy details how an employee, agency staff member, contractor, consultant or trainee may raise a concern about wrongdoing in the workplace.

Health and Safety Policy Statement – which reflects the Company’s commitment to protecting the health and safety of employees, contractors and customers.

Health, Safety and Wellbeing

W.R. Kennedy & Company’s aim is to make sure everyone gets home safely and the Company has very high safety standards for both employees and contractors.

STAFF EDUCATION AND AWARENESS

During the incoming year refresher training is to be provided on the identification and prevention of slavery and human trafficking to all employees in the Procurement Department. Annual briefing to all employees on the Company’s Modern Slavery policy also is to be completed in 2023-24.

MEASURING EFFECTIVENESS

In order to understand how effective these controls are in ensuring that modern slavery does not exist within W.R. Kennedy & Company’s supply chains, it has been planned to conduct audits of suppliers in high-risk industries and/or countries.

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