For the Financial Year ending 31 October 2025
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps taken by Wynnstay Group Plc and its subsidiaries (‘Wynnstay’ or ‘the Group’) during the financial year ended 31 October 2025, to help prevent modern slavery and human trafficking in its business and supply chains.
Modern slavery is a serious violation of fundamental human rights and includes slavery, servitude, forced or compulsory labour, and human trafficking. Wynnstay is committed to acting ethically and responsibly, and to maintaining effective systems and controls aimed at reducing the risk of such practices occurring within its operations or supply chains.
Our Business and Supply Chains
Wynnstay Group Plc is a UK-based agricultural supplies and services group, providing a range of products and services to farming and rural businesses. The Group’s operations are primarily based in the United Kingdom.
Wynnstay’s supply chains include suppliers of goods for resale and suppliers of goods and services not for resale, including professional services, logistics, packaging, equipment, utilities and other operational support.
While much of the Group’s supply chain is UK-based, certain products, components or inputs may be sourced from overseas markets, and Wynnstay recognises that modern slavery risks can arise at different stages of extended supply chains.
Our policies and standards
Wynnstay is committed to conducting business ethically, responsibly and with respect for human rights. The Group does not tolerate modern slavery, forced labour or human trafficking in any form.
This commitment is underpinned by a developing supplier governance and assurance framework, supported by key documents including:
- the Wynnstay Supplier Code of Conduct, which sets out expectations regarding ethical behaviour, labour standards and human rights;
- contractual requirements embedded within Wynnstay’s supplier agreements;
and - this Modern Slavery and Human Trafficking Statement.
Suppliers are expected to comply with all applicable labour and human rights laws and, where local legal requirements are less stringent, to meet the standards set out by Wynnstay.
Wynnstay maintains a confidential internal whistleblowing platform (‘Wynnstay SpeakUp’), delivered through Deloitte’s independent service, enabling colleagues to raise concerns, including any suspicions of modern slavery risks linked to the Group’s operations or supply chain.
Due diligence and supplier governance
During the year, the Group approved a refreshed supplier governance framework designed to strengthen consistency, evidence and oversight across the supplier base.
This framework is being rolled out on a phased basis, prioritising areas of higher risk and materiality.
As part of this framework, suppliers will be expected to:
- acknowledge and comply with the Supplier Code of Conduct;
- complete a Modern Slavery Questionnaire as part of onboarding or re-onboarding activity; and
- enter into Wynnstay’s standard contractual arrangements, which include provisions relating to ethical standards, audit rights, termination and remedies for breach.
Where responses or other information indicate an elevated risk, Wynnstay may request additional information, enhanced due diligence or further assurance from the supplier. Supplier information and due diligence records will be retained centrally to support ongoing oversight and review.
Risk assessment and management
The Group recognises that modern slavery risks vary by sector, geography, product type and labour practices.
Historically, the Group’s risk exposure has been considered lower due to the predominantly UK-based nature of its operations and supplier base. However, Wynnstay recognises that risk cannot be assumed away and that supply chains may evolve over time.
Risk assessment is informed by factors such as:
- the nature of goods or services supplied;
- the use of subcontracting or labour providers;
- geographic sourcing considerations; and
- supplier responses to due diligence enquiries.
Where risks are identified, Wynnstay seeks to address them through engagement, contractual controls, monitoring or, where appropriate, escalation and termination.
Wynnstay did not identify any instances or indicators of modern slavery or human trafficking within its operations or direct supply chain during the year.
Training and awareness
Wynnstay recognises the importance of awareness and understanding in preventing modern slavery. During 2025/26, the Group will embed proportionate guidance for relevant colleagues as part of the phased implementation of its supplier governance and assurance framework.
Measuring effectiveness
The Group continues to develop its approach to monitoring and assessing the effectiveness of its actions to prevent modern slavery. This includes:
- tracking supplier completion of due diligence requirements;
- reviewing supplier responses and identified risks;
- using contractual rights to require remediation or take action where standards are not met; and
- maintaining an evidence base to support governance, reporting and assurance.
Forward priority (2025/26): Wynnstay will continue the phased rollout of its supplier governance framework, with a particular focus on securing Supplier Code of Conduct acknowledgement and modern slavery due diligence documentation across priority supplier categories.
As part of this work, Wynnstay has opened discussions with Sedex as a potential independent assurance partner, to explore how proportionate third-party verification may be applied within higher-risk areas of the Group’s widening supplier profile.
Wynnstay did not identify any confirmed instances of modern slavery or human trafficking within its operations or direct supply chain during the year. Wynnstay recognises that preventing modern slavery is an ongoing process and remains committed to continuous improvement.
Approval
This statement was approved by the Board of Wynnstay Group Plc on 19 February 2026 and signed on its behalf by the Chairman on that date. It will be reviewed annually.
Steve Ellwood
Chairman
Wynnstay Group Plc
19 February 2026
For the Financial Year ending 31 October 2024
Organisation Structure and Supply Chains
This statement sets out Wynnstay Group Plc and its subsidiary companies (“the Group”) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.
A leading supplier of agricultural products, the Group is dedicated to providing a professional, reliable, and efficient service to a range of customers including farmers and rural dwellers across a wide trading area, currently limited to the UK. Committed to national growth, the Group conducts its activities ethically and with honesty and with integrity but recognises the potential for abuses to occur within extended supply chains and wishes to do all that it can to prevent modern slavery and human trafficking acts. The Board will not tolerate business relationships with organisations knowingly involved with such abuse.
This statement therefore sets out the Group’s approach to understanding the potential risks of such abuses, and the steps in place and to be implemented, to prevent modern slavery or human trafficking events occurring within its own business and associated supply chains. This statement relates to intentions and actions taken during the financial year, and to the future development of procedures for identifying risks and preventing abuses.
In accordance with Section 54 of the Modern Slavery Act 2015, the Board continues to seek adequate transparency within its own business units and direct supply chains to identify actual instances or risks of slavery or human trafficking. The Board has not currently extended efforts to identify such risks beyond the immediate direct supply chains due to resource and practical limitations, although dialogue on such matters continue with appropriate links in more complex supply arrangements.
Policies in Relation to Modern Slavery and Human Trafficking
The Group’s Modern Slavery Policy complies with the Act 2015 and incorporates a risk assessment protocol which identifies and assesses potential risk within the organisation. Appropriate investigative and auditing processes should a risk be identified, will be conducted immediately, as necessary and reported to the Board by a member of the Executive Committee (ExCo). Appropriate investigative and auditing processes commensurate to the scale of the enterprise and risk, are executed, as necessary.
The Group’s Whistleblowing Policy encourages all workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
Due Diligence Processes
The Wynnstay Board has committed to preventing modern slavery and human trafficking acts from its corporate activities, and to ensure that its national and international supply chains are free from such abuses. Where possible the organisation prefers to build long standing relationships with suppliers, where through a strengthening of trading commitments, we can make clear our expectations of business behaviour.
During the last year, the Group continued to review its primary trading partners with a view to identifying relationships where a risk may exist even if it had not been previously identified. During our reviews and engagements with suppliers, a categorisation process is used to risk assess the respective entity into low, medium or high risk for possible modern slavery or human trafficking concerns. Further investigation or research would be carried out into any entities classed as medium or high risk before commencing or continuing to trade with that entity. During the year, no relationships were identified as being in this these categories.
The Board also recognise that concerns about modern slavery are not just limited to the Group’s supply chains but may also be a risk within the Group’s own employment environment, and particularly with regard to temporary or agency staff use. The HR function continues to assess hiring practices and only approved agencies with appropriate employment due diligence processes have been used during the previous year.
Risk Assessment and Management
Standard trading conditions for all new relationships incorporate appropriate confirmations on these matters, with a view to normalising the consideration of modern slavery and human trafficking risks in the usual commercial contract terms for our business.
All suspected cases of modern slavery and human trafficking will be reported to a member of the Executive Committee (ExCo immediately following any concerns, and any such report will be investigated on a case-by-case basis, with appropriate remedial action taken immediately).
Key Performance Indicators to Measure Effectiveness of Steps Being Taken
A system is in place whereby the supply chain verification process is completed prior to the supplier entering the companies supply chain and, the organisation continues to evaluate all existing suppliers for evidence of continued ethical trading behaviour.
Training on Modern Slavery and Trafficking
The organisation has identified appropriate colleagues requiring training on modern slavery who are provided with sufficient training where appropriate, enabling them to identify risk and ensure the expectations of the procurement policy and its associated processes are understood at all levels across the Group.
Board Approval
Modern slavery is a pernicious crime that targets the most vulnerable and preys on the weak, and the Board wants to see it irradicated from our industry as a whole, both from an ethical perspective as well as ensuring a fair competitive playing field.
This statement has been approved by the Company's Board of Directors, who have assessed that current risk with regard to modern slavery and human trafficking abuse within the Group and its direct supply chain is low due to the nature of its continued operations.
Rob Thomas
Chief Financial Officer
Wynnstay Group Plc
23 December 2024