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.
Steven Esom
Chairman
Wynnstay Group Plc
19 February 2026