Modern Slavery Policy

Last updated 23rd October 2023

Modern Slavery Policy Introduction


This statement sets out AT Brady Holdings Limited, company registration number 10935683, (hereinafter referred to as “Admiral Taverns”) actions to understand and to put in place steps to identify potential risks and the steps in place to ensure that there is no slavery or human trafficking in its own business and its supply chains. Admiral Taverns is an independent tenanted and leased pub company which operates in England, Wales and Scotland only and works on a financial year from 1st June to 31st May. This statement relates to actions and activities during the financial year ending May 2023. In July 2021, Admiral Taverns acquired the Hawthorn Leisure group and integrated the two businesses. The combined group operates under AT Brady Holdings Limited as the parent company. This statement is made pursuant to s54 of the Modern Slavery Act 2015 and applies to all subsidiary companies and group companies who are required to make a statement under this legislation, including Admiral Taverns Ltd (company registration number 05438628).

As part of the hospitality sector, Admiral Taverns recognises that we have a responsibility to lead by example in our approach to slavery and human trafficking and we are committed to preventing this in our activities, and we take our responsibility seriously.

Organisational structure and supply chains

Admiral Taverns is an ambitious, independent community pub company that operates in the UK only and is headquartered in Chester. We own and manage circa 1,500 leased, tenanted and operator managed pubs around the United Kingdom (UK). We are committed to continue to invest in our pub portfolio through our CAPEX programs and invest in our people. Admiral’s unique operational approach has earnt industry recognition through the Publican Awards with the group awarded Best Leased and Tenanted Pub Company in 2019, 2016 and 2013. The group was also a finalist in 2023 in the Best Community Pub Operator and Best Tenanted / Leased Pub Company (501+ Sites) and ranked highly commended as Best Community Pub Operator in 2017.

Being UK focused and community centric, Admiral Taverns considers its risk of slavery and human trafficking to be low. Our pubs are run independently by licensees or operators who employ their staff directly. Our recruitment processes ensure that appropriate checks have been undertaken to ensure prospective licensees have the right to work in the UK. These individuals have the support of our Business Development Managers (BDM) and our internal teams with any concerns. Our BDM’s have a manageable number of pubs within their geographical remit to ensure that they can remain in close contact with each one. If any Admiral employee or representative becomes suspicious of any illegal activity or has any concerns, they will escalate the matter. Many of our licensees operate as tied pubs, using our approved suppliers to order their stock. In addition, we offer licensees an enhanced service charge to help provide them statutory compliance testing through our suppliers.

Admiral Taverns’ suppliers and contractors range from large drinks manufacturing companies, to professional advisers and agents and also regional and local contractors who provide services to Admiral pubs. Admiral conducts due diligence on new suppliers to our business. All of our suppliers and contractors are based in the British Isles and Admiral engages with them, on the basis that we are committed to working only with suppliers and contractors who treat their obligation to modern slavery with the utmost importance.

Given the nature of our business and the suppliers that we deal with, we strongly believe the risk of non-compliance in our business to be low, but nevertheless, it is an issue upon which we remain vigilant. We believe the area of most risk in relation to modern slavery and human trafficking to be through unknown external suppliers to our pubs, for example if licensees are not tied for beer supplies or employ their own contractors for property works. This is due to these suppliers being unknown to us and out of our control. We will continue to mitigate this by raising awareness of modern slavery with our licensees and they are required to adhere to all UK regulations within their contracts with Admiral Taverns.

Responsibility for our anti-slavery initiatives are as follows:


  • Admiral Taverns has a Modern Slavery Policy that it operates alongside this statement and is available to employees and issued to suppliers Admiral Taverns ensures awareness of this policy internally through its Human Resources team and Compliance Committee and externally through the relevant business areas. We encourage all who we work with to report any concerns in this area. The responsibility for our Modern Slavery Policy and Statement sits with the Executive Directors, Compliance Committee and Compliance The policies are developed in connection with relevant business areas and are reviewed regularly and signed off by the Operating Board of Admiral Taverns, as required.
  • We have several policies that protect our employees including our Employee Privacy Policy, Anti Bribery Policy, Equal Opportunities Policy, Anti-Harassment Policy, Grievance Policy and Disciplinary Policy.

Risk Assessment:

  • Risks are considered and discussed at the Compliance Committee and with any relevant members of the Operating Board.

Investigations/due diligence/performance indicators:

  • We have had no known or suspected instances of slavery and human trafficking. Any concerns should be raised to management level and the Compliance Officer. This will then be investigated by the Compliance Committee.
  • Admiral Taverns operates under the Pubs Code Regulations and are registered with the Financial Conduct Authority (FCA) for certain regulated activity. We have an appointed Senior Manager with the FCA and complete Conduct rules training annually with relevant Conduct staff. In addition, our companywide values, developed by our team and in line with our culture are One Team, We Care and Make a Difference.
  • In regard to recruitment/agency/temporary workers we use only specified, reputable employment agencies to source workers. Our performance indicator in this regard is via our HR team who ensure a legal right to work within the UK is in place as part of this process. We largely employ individuals directly to ensure adherence.
  • We provide our Modern Slavery Policy and statement to our suppliers through the Property and Commercial functions.
  • Within our property function, our performance indicator is that suppliers are provided to confirm their understanding and commitment to our Modern Slavery Policy through our Tender Document Framework. We are clear that violations of our Framework Agreement will lead to the termination of the business relationship.


  • We provide our policy and statement to employees and our statement to suppliers to enable them to better understand and respond to slavery and human trafficking risks.
  • We raise awareness of modern slavery through our policy and statement. This is issued internally, and our performance indicator in this regard is that all employees are required to confirm that they have read the documents. Included with this is how to raise any requests for further training and how to identify and escalate concerns.
  • Our operators within our Operator Managed business are provided with access to eLearning modules on modern slavery via our approved eLearning provider.
  • We also make eLearning modules on modern slavery via our approved eLearning provider available to purchase for leased and tenanted licensees or we provide it to them free of charge if they take out our premium maintenance package.


The Executive Directors of Admiral Taverns have approved this statement and Modern Slavery Policy in October 2023 and are committed to ensuring there is no form of modern slavery within our business and to review this statement annually.

Signed by Board Member/Executive Director:

Andrew Clifford

Property and Strategy Director

Date:  23 October 2023