Corporate Social Responsibility

Slavery and Human Trafficking Statement

Organisation Structure and Activities

Reabrook Ltd is an Employee Ownership Trust based in Moira, at the heart of the National Forest. We have over 50 years’ experience manufacturing aerosol and liquid chemical products across the automotive, household, industrial, janitorial, and personal care sectors.

We employ approximately 220 people and operate primarily within the UK, supplying products to customers globally. Our end-to-end service includes product development, design, sourcing, manufacturing, quality assurance, and logistics.

We are committed to ensuring that all individuals connected to our business are treated with dignity and respect at all times.

Our Commitment

Reabrook Ltd is committed to preventing modern slavery and human trafficking in all areas of our business and supply chains. The Managing Director acknowledges their responsibilities under the Modern Slavery Act 2015 and is fully committed to identifying, mitigating, and addressing risks.

We do not knowingly engage with, or support, any organisation involved in slavery, servitude, forced labour, or human trafficking.

Policies and Governance

Our commitment is supported by a framework of policies and procedures that are reviewed annually and approved by senior leadership. These include:

Human Rights Policy
Whistleblowing Policy
Anti-Bribery Policy
Health, Wellbeing and Safety Policy
Corporate Social Responsibility Policy

We align with the Ethical Trading Initiative (ETI) Base Code and are a registered member of SEDEX (4-pillar). We ensure compliance with all relevant legislation and promote ethical and responsible business practices across our operations.

Due Diligence and Risk Assessment

We take a risk-based approach to identifying and addressing modern slavery within our business and supply chain. This includes:

Ethical supplier questionnaires covering labour standards, health and safety, and business ethics
Participation in independent SMETA ethical audits, with results shared via SEDEX
Ongoing monitoring of labour providers to ensure compliance with legal and ethical standards
Zero tolerance for any organisation found to be knowingly involved in modern slavery

Supply Chain Management

We are committed to building a transparent and responsible supply chain. Our approach includes:

Conducting due diligence on all new suppliers and regular reviews of existing suppliers
Requiring suppliers and contractors to adhere to our ethical standards and complete an Ethical Supplier Questionnaire
Supporting local sourcing where possible, while managing an international supply chain across Europe and North America
Maintaining RSPO certification
Supporting animal welfare, including collaboration with Cruelty Free International
Ensuring compliance with relevant product regulations, including UK and EU cosmetic regulations where applicable
Training relevant employees in human rights and supply chain due diligence, including through the Stronger Together initiative

Our People

We are committed to raising awareness of modern slavery and human trafficking among our employees. This includes:

Participation in the Stronger Together initiative
Providing training and awareness programmes, including internal communications and video resources
Developing internal expertise through externally trained employees who share knowledge across the business

Employees are encouraged to report concerns, with protections in place through our whistleblowing procedures.

Continuous Improvement

We are committed to continuously improving our approach to tackling modern slavery through regular policy reviews, enhanced due diligence, and ongoing training. Responsibility for implementation sits with senior management, with oversight from the Board.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Reabrook Ltd’s slavery and human trafficking statement for the financial year ending 31 December 2025.

This statement has been approved by: Kat Minshull, Managing Director, Reabrook Ltd

Date: 19^th May 2026

Anti-Bribery

What is a bribe?

A bribe is a financial or other type of advantage that is offered or requested with the:

Intention of inducing or rewarding improper performance of a function or activity;
Knowledge or belief that accepting such a reward would constitute the improper performance of such a function or activity.

A relevant function or activity includes public, state or business activities or any activity performed in the course of a person’s employment, or on behalf of another company or individual, where the person performing that activity is expected to perform it in good faith, impartially, or in accordance with a position of trust.

A criminal offence will be committed under the Bribery Act 2010 if:

An employee or associated person acting for, or on behalf of, Reabrook offers, promises, gives, requests, receives or agrees to receive bribes; or An employee or associated person acting for, or on behalf of, Reabrook offers, promises or gives a bribe to a foreign public official with the intention of influencing that official in the performance of his/her duties (where local law does not permit or require such influence); and Reabrook does not have the defence that it has adequate procedures in place to prevent bribery by its employees or associated persons.

What is prohibited?

Reabrook prohibits employees or associated persons from offering, promising, giving, soliciting or accepting any bribe. The bribe might be made to ensure that a person or company improperly performs duties or functions (for example, by not acting impartially or in good faith or in accordance with their position of trust) to gain any commercial, contractual or regulatory advantage for Reabrook in either obtaining or maintaining Company business, or to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.

This prohibition also applies to indirect contributions, payments or gifts made in any manner as an inducement or reward for improper performance, for example through consultants, contractors or sub-contractors, agents or sub-agents, sponsors or sub-sponsors, joint-venture partners, advisors, customers, suppliers or other third parties.

Employees and associated persons conducting business on behalf of Reabrook outside the UK may be at greater risk of being exposed to bribery or unethical business conduct than UK-based employees. Employees and associated persons owe a duty to Reabrook to be extra vigilant when conducting international business.

Records

All accounts, receipts, invoices and other documents and records relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts may be kept “off the record” to facilitate or conceal improper payments.

Facilitation Payments

Reabrook prohibits its employees or associated persons from making or accepting any facilitation payments. These are payments made to government officials for carrying out or speeding up routine procedures. They are more common overseas. Facilitation payments are distinct from an official, publicly available fast-track process. Facilitation payments constitute bribes and may not be made at any time irrespective of prevailing business customs in certain territories.

Corporate Entertainment, Gifts, Hospitality and Promotional Expenditure

Reabrook permits corporate entertainment, gifts, hospitality and promotional expenditure that are undertaken:

For the purpose of establishing or maintaining good business relationships;
To improve the image and reputation of Reabrook;
To present Reabrook’s goods/services effectively;

Provided that it is:

Arranged in good faith
Not offered, promised or accepted to secure an advantage for Reabrook or any of its employees or associated persons or to influence the impartiality of the recipient.

Reabrook will authorise only reasonable, appropriate and proportionate entertainment and promotional expenditure. Any gifts, rewards or entertainment received or offered from clients, public officials, suppliers or other business contacts should be reported immediately to the Managing Director. If an employee or associated person wishes to provide gifts to suppliers, clients or other business contacts, prior written approval from the Managing Director is required, together with details of the intended recipients, reasons for the gift and business objective. These will be authorised only in limited circumstances.

Employees and, where applicable, associated persons must supply records and receipts, in accordance with Reabrook’s expenses policy.

This policy does not prohibit:

Normal and appropriate hospitality and entertainment with clients (please see Reabrook’s expenses policy)
The use of any recognized fast-track process that is publicly available on payment of a fee.
Any such practices must be proportionate, reasonable and made in good faith. Clear records must be kept.

Risk Management

Reabrook has established detailed risk management procedures to prevent, detect and prohibit bribery. Reabrook will conduct risk assessments for each of its key business activities on a regular basis and, where relevant, will identify employees or officers of Reabrook who are in positions where they may be exposed to bribery.

Reabrook will identify high-risk areas, for example projects undertaken in high-risk countries, tenders for work and those working on high-value projects.

Reabrook will:

Regularly monitor “at risk” employees and associated persons
Regularly communicate with “at risk” employees and associated persons
Undertake extensive due diligence of third parties and associated persons
Communicate its zero-tolerance approach to bribery to third parties, including actual and prospective customers, suppliers and joint-venture partners.

Charitable and Political Donations

Reabrook considers that charitable giving can form part of its wider commitment and responsibility to the community. Reabrook supports many charities that are selected in accordance with objective criteria, following a risk assessment. Reabrook may also support fundraising events involving employees.

Reporting Suspected Bribery

Reabrook depends on its employees and associated persons to ensure that the highest standards of ethical conduct are maintained in all its business dealings. Employees and associated persons are required to cooperate with Reabrook’s risk management procedures and to report suspicions of bribery to the Managing Director. While any suspicious circumstances should be reported, employees and associated persons are required particularly to report:

Any suspected or actual attempts at bribery
Concerns that other employees or associated persons may be being bribed
Concerns that other employees or associated persons may be bribing third parties, such as clients or government officials
Close family, personal or business ties that a prospective agent, representative or joint-venture partner may have with government or corporate officials, directors or employees
A history of corruption in the country in which the business is being undertaken
Requests for cash payments
Requests for unusual payment arrangements, for example via a third party
Requests for reimbursements of unsubstantiated or unusual expenses
A lack of standard invoices and proper financial practices.

If an employee or associated person is in any doubt as to whether a potential act constitutes bribery, the matter should be referred to the Managing Director. Employees should report in writing any instances of suspected bribery to the Managing Director. Any such reports will be thoroughly and promptly investigated by the Managing Director in the strictest confidence. Employees and associated persons will be required to assist in any investigation into possible or suspected bribery.

Employees will also be required to comply with Reabrook’s whistle-blowing policy. Employees or associated persons who report instances of bribery in good faith will be supported by Reabrook. Reabrook will ensure that the individual is not subjected to detrimental treatment because of his/her report.

Reabrook will fully investigate any instances of alleged or suspected bribery. Reabrook will invoke its disciplinary procedures where any employee is suspected of bribery, and proven allegations may result in a finding of gross misconduct and immediate dismissal. Reabrook may terminate the contracts of any associated persons, including consultants or other workers who act for, or on behalf of, Reabrook who are found to have breached this policy.

Reabrook may also report any matter to the relevant authorities, including the Director of Public Prosecutions, Serious Fraud Office, Revenue and Customs Prosecutions Office and the police. Reabrook will provide all necessary assistance to the relevant authorities in any subsequent prosecution.

Review of Procedures and Training

Reabrook will regularly communicate its anti-bribery measures to employees and associated persons. Reabrook will set up training sessions where applicable. The Managing Director is responsible for the implementation of this policy.

The Managing Director will monitor and review the implementation of this policy and related procedures on a regular basis, including reviews of internal financial systems, expenses, corporate hospitality, gifts and entertainment policies. Employees and those working for or on behalf of, Reabrook are encouraged to contact the Managing Director with any suggestions, comments or feedback that they may have on how these procedures may be improved.

Equal Opportunities

Reabrook is an Equal Opportunities employer. Reabrook commits itself to promote and develop equal opportunities and will keep under review its policies, procedures and practises to ensure that they accord with the principles of equal opportunities and are consistently applied.

Reabrook recognises that discrimination is unacceptable and it is in Reabrook’s own best interest, as well as the interests of its employees, to utilise the skills of the total workforce.

The aim of the Equal Opportunities Policy is to ensure that no present or future employee or job applicant receives less favourable treatment on the grounds of race, colour, creed, religion, ethnic or national origin, nationality, sex, marital status, disability, age, sexuality, sexual orientation or social status, or is disadvantaged by any conditions or requirements which cannot be shown as necessary.

In the promotion of the policy we will endeavour to meet the full statutory requirements relating to Equal Opportunities.

All staff of Reabrook will accept personal responsibility for practical application of the policy. Responsibility for its implementation will rest with the Managing Director.

Monitoring

Reabrook will create and maintain employment records in order to monitor the progress of this policy. This will involve the collection and classification of information regarding the ethnic origin, gender and disability of all current employees in line with current Data Protection legislation. This information may be passed to government agencies or may be collated and provided to auditing bodies. No identifying information will be revealed.

Recruitment

The purpose of Reabrook’s Recruitment and Selection Procedure is to ensure that highest standards of recruitment and selection practice are followed in the recruitment and promotion of employees. Line Managers shall notify the HR Department of recruitment needs at the earliest opportunity.

Applications

All internal and external applications will be reviewed by Department Manager and HR. Selection of candidates will be made for interview based on suitability in comparison with Job Description and person specification. It is the responsibility of the Department Manager and HR to ensure that the selection of candidates for interview complies with Reabrook’s Equal Opportunities Policy. There shall be no discrimination on the grounds race, colour, creed, religion, ethnic or national origin, nationality, sex, marital status, disability, age, sexuality, sexual orientation or social status. All candidates will receive a written response to their application within a 4-week time period.

Recruitment and Selection

The intention of the recruitment procedure is to ensure the most appropriate response to any vacancy in Reabrook. Reabrook wishes to ensure the highest quality of candidates and will advertise the vacancies within the organisation. Jobs will be advertised via job centres, careers service, local press and use appropriate external vacancy advertising outlets. The selection process is of crucial importance and must therefore be carried out according to objective, job related criteria. The effectiveness of the policy will be determined to a great extent by this aspect of the employment procedure. Reabrook will endeavour through appropriate training to ensure that employees making selection decisions will not discriminate in making these decisions.

Proof of Identity

To comply with the Asylum and Immigration Act 1996 Reabrook must obtain evidence from new employees of their right to work in the UK. This evidence will normally consist of a current passport. If they are unable to provide a passport Reabrook will need to see an original birth certificate showing the name of at least one parent, plus one other form of identification showing a National Insurance number. All documentation must be produced on their first day of employment.

Training and Promotion

All steps will be taken to ensure equal access to opportunities for training and promotion. Reabrook will endeavour to provide appropriate training to enable staff to perform their jobs efficiently and pursue career development opportunities. Training and guidance will be given to members and senior staff of Reabrook to increase awareness of their role. Training and guidance in appropriate techniques will be provided for staff involved in recruitment and selection.

Human Rights Policy Statement

Reabrook Ltd is committed to respecting, protecting, and promoting human rights across all areas of our operations. We are guided by the principles set out in the UN Universal Declaration of Human Rights, the UN Global Compact, the UN Guiding Principles on Business and Human Rights, and the ILO Declaration on Fundamental Principles and Rights at Work.

We recognise our responsibility to uphold these standards and to prevent, identify, and address any adverse human rights impacts linked to our business activities, relationships, and supply chains.

Our Employees

We are committed to providing a safe, inclusive, and respectful working environment where all employees are treated with dignity and fairness. We have zero tolerance for discrimination, harassment, bullying, victimisation, forced labour, or exploitation of any kind.

Our policies—including our Corporate Social Responsibility Policy, Company Handbook, and HR procedures—support equal opportunity and protect employees regardless of background, identity, or beliefs.

We are committed to preventing modern slavery, including forced labour and human trafficking, and support initiatives such as Stronger Together. Employees are encouraged and supported to raise concerns, with clear reporting channels and protection from retaliation.

Our Supply Chain

We expect our suppliers and business partners to uphold the same high standards of human rights. Our supplier onboarding and review processes assess compliance with ethical and human rights requirements, including modern slavery risks. We will take appropriate action where standards are not met.

Our Customers and Business Relationships

We seek to work with customers and partners who share our commitment to ethical practices and human rights. We support transparency, audits, and collaborative efforts to strengthen human rights performance across our networks.

Communities and Stakeholders

We aim to operate responsibly within the communities where we work, contributing positively to society and complying with all applicable legal and regulatory requirements. We engage with stakeholders to understand and improve our social impact.

Governance and Continuous Improvement

We are committed to continuous improvement in our human rights approach through regular review of our policies, risk assessments, and practices. Responsibility for this policy sits with senior management, with oversight of implementation and compliance across the business.

Approved by: Kat Minshull,Managing Director, Reabrook Ltd