Modern slavery statement

D. McGhee & Sons Limited
Anti-Modern Slavery Statement

ORGANISATION
This statement applies to all companies within and associated to D. McGhee & Sons Limited (referred to in this statement as ‘The Group’). The information included in the statement refers to the financial year 3rd August 2025 – 1st August 2026.

DEFINITIONS
The Group considers that modern slavery encompasses:
• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or to have restriction placed on freedom of movement.

COMMITMENT
The Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Group understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Group does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in Scotland.

ORGANISATIONAL STRUCTURE
The McGhee Group is controlled by a Board of Directors comprising a Managing Director, Operations Director, Production Director, Finance Director, Sales Director, and Commercial Director. The Senior Leadership Team includes a Head of Engineering and a Head of Human Resources, as well as Managing Directors for Kerr’s and Fergusons, and Business Managers for Fords and Wallace. All entities and senior personnel ultimately report to the McGhee Group Board of Directors.

The Group operates five sites across Scotland. These include three production sites — McGhee’s (Head Office and main site) in Glasgow, Fergusons in Kilmarnock, and Kerr’s in Wishaw — and two distribution-only sites: Fords in Edinburgh and Wallace in Dundee.

McGhee’s, Fords, and Wallace operate under the McGhee’s legal entity, while Fergusons and Kerr’s operate as separate legal entities within the Group.

The Group’s principal activity is the production of fresh bakery goods such as morning rolls, cakes, potato scones, and other craft baked products. These are distributed to supermarkets, restaurants, cafés, and some customers directly. The Group does not operate an in-store retail outlet. Demand for its products is steady and consistent throughout the year and is not seasonal.

All operations and associated labour activities are carried out entirely within the United Kingdom, across its five Scottish sites in Glasgow, Kilmarnock, Wishaw, Edinburgh, and Dundee. The labour supplied to the Group in pursuance of its operation is carried out wholly in Scotland, in the UK.

ORGANISATIONAL POLICIES
The Group has policies that reinforce our commitment to preventing modern slavery, including:
• Modern Slavery Policy
• Corporate Social Responsibility Statement
• Equality & Diversity Policy
• Anti-Bribery & Corruption Policy
• Whistleblowing Procedure

Our recruitment process is robust and consistently applied, with full right-to-work checks carried out for all employees and agency workers. These checks support compliance with UK legislation and help safeguard against human trafficking and forced labour.

SUPPLY CHAIN STRUCTURE
In order to fulfil its activities, the McGhee Group’s main supply chains relate to the sourcing of ingredients, packaging, and equipment necessary for the production and distribution of bakery goods. These supplies are primarily sourced from UK-based suppliers. The Group understands that some of its first-tier suppliers may engage with additional lower-tier suppliers, and as such, the Group is committed to ongoing due diligence and maintaining responsible procurement practices within its supply chain.

SUPPLIER DUE DILIGENCE
The Group recognises the importance of maintaining oversight of its supply chain and ensuring that the suppliers we work with operate ethically and in accordance with the Modern Slavery Act 2015. As part of our due diligence processes, we take the following steps:

• Supplier Ethical Questionnaire – All new suppliers are required to complete the Group’s Supplier Approval Questionnaire. This includes declarations relating to ethical trading, use of child labour, fair treatment of workers, non-discrimination, wage compliance, and labour practices. Suppliers must confirm that they do not engage in forced labour, child labour, human trafficking, or any form of exploitation.

• SEDEX participation and ethical data review – Where applicable, suppliers are asked to provide their SEDEX membership number so that the Group can review Self-Assessment Questionnaires (SAQs), ethical risk ratings, and any identified non-conformances relating to labour standards or modern slavery indicators.

• Policy and accreditation checks – Suppliers are requested to provide copies of relevant policies and certifications, such as Ethical Trading Policies, BRC accreditation, and other third-party standards that demonstrate responsible and compliant business practices.

• Ongoing approval and monitoring – Our Supplier Approval Questionnaire requires suppliers to confirm that they have procedures in place for managing labour standards, worker welfare, and ethical risks. Suppliers are expected to inform the Group of any significant changes to their operations, certifications, or ethical compliance status. These measures allow the Group to maintain confidence that suppliers meet expected ethical standards without relying on internal physical audits, and they reflect our commitment to responsible sourcing and preventing modern slavery within our supply chain.

ASSESSING AND MANAGING RISK
The Group considers its main exposure to the risk of slavery and human trafficking to exist in its outsourced labour arrangements through agencies, as this involves the provision of temporary or contract workers in roles where oversight is less direct and the risk of exploitation could be higher. However, the Group mitigates this risk by using only agencies that hold a valid Gangmasters and Labour Abuse Authority (GLAA) licence and therefore considers the likelihood of such practices occurring to be very low.

In general, the Group considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

WHISTLEBLOWING AND REPORTING CONCERNS
The Group maintains a Whistleblowing Procedure and secure reporting channels which allow employees to raise concerns confidentially or anonymously, including concerns related to modern slavery or unethical behaviour. All reports are taken seriously, investigated promptly, and handled without detriment to the individual raising the concern.

TRAINING
The Group provides basic training and guidance on modern slavery to employees involved in recruitment and agency management. This includes awareness of the signs of forced labour, right-to-work verification, and the process for escalating concerns. Training needs are reviewed annually, and additional guidance is provided as required or requested.

MEASURING EFFECTIVENESS
We assess the effectiveness of our approach to preventing modern slavery by monitoring several indicators, including: any whistleblowing reports linked to modern slavery concerns; any non-conformances identified during internal audits; ethical non-conformances raised through SEDEX assessments; and any external alerts relating to potential modern slavery issues. Our monitoring during this period did not identify any instances of exploitation, modern slavery, or human trafficking.

LOOKING AHEAD
Over the 2025/26 financial year, the Group will continue to strengthen awareness of modern slavery across the organisation. This will include ongoing colleague training and communication, refresher sessions for HR and operational teams on recognising potential warning signs, proactive checks for any modern slavery red flags, and supporting awareness initiatives such as Anti-Slavery Day.

Date of approval by Board of Directors: 18th August 2025