Modern Slavery Policy

Last updated 16th March 2022

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 and ensure that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year ending May 2021. 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.

In previous years, Admiral Taverns has published its statement no later than October. We recognise that we are publishing this statement later than expected. This is because of reduced staff capacity during the coronavirus pandemic. Our next statement will be issued in September 2022 to support the Government’s review of the modern slavery reporting requirements. This policy will cover the reporting period 1 April 2021 to 31 March 2022.

As part of the hospitality sector, Admiral Taverns recognises that we have a responsibility to take a robust approach to slavery and human trafficking and we are committed to preventing this in our activities, and we continued to take our responsibility very seriously during the coronavirus pandemic.

Organisational structure and supply chains

This statement covers the activities of AT Brady Holdings Limited operating under the name Admiral Taverns. In July 2021, Admiral Taverns acquired the Hawthorn Leisure group and is integrating the two businesses. The combined group will operate under AT Brady Holdings Limited as the parent company and this statement is prepared for the enlarged group.

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 1,600 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 with the group awarded Best Leased and Tenanted Pub Company in 2019, 2016 and 2013 and ranked highly commended as Best Community Pub Operator in 2017. With individual pubs within our estate being recognised by the Great British Pub Awards and as local community heroes. The group has been consistently highly rated by its licensees in the industry’s annual KAM media survey, exceeding the scores of all its national peers regulated by the Pubs Code.

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 have any concerns, they will escalate the matter. Many of our licensees operated 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 the Admiral pubs. Admiral conducts due diligence on new suppliers to our business. All of our suppliers and contractors are based in the UK and Admiral engages with them, advising that we have a Modern Slavery Policy and that we are committed to working only with suppliers and contractors who treat their obligation to modern slavery with the utmost importance. Admiral Taverns’ will not work with any organisation that refuses to commit to the subject of modern slavery.

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 requiring them to adhere to all UK regulations within their contracts.

Responsibility for our anti-slavery initiatives are as follows:

  • Policies: The responsibility sits with the Executive Directors, Compliance Committee and Compliance Officer. The policies are developed in connection with relevant business areas and are reviewed regularly as required.
  • Risk Assessment: Risks are considered and discussed at the Compliance Committee and with any relevant members of the Operating Board.
  • Investigations/due diligence: 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.
  • Training: 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.

 

Relevant policies and Due Diligence

Admiral Taverns has a Modern Slavery Policy that it operates alongside this statement and is available to employees and issued to suppliers on an ongoing basis. Admiral Taverns ensures awareness of this policy through its Human Resources team and Compliance Committee. We encourage all our workers and other business partners to report any concerns in this area.

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.

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 are We Care, We are One, We Dream Big, We Deliver.

We work with suppliers to ensure that they meet the standards set out within our Modern Slavery Policy and statement. These policies are provided to suppliers through our Commercial Director and Head of Property. Within our property function, our performance indicator is that this forms part of the review process for new contractors who wish to tender for work. They are provided to confirm their understanding and commitment to our Modern Slavery Policy through our Tender Document Framework. We are clear that serious violations of our Framework Agreement will lead to the termination of the business relationship.

In regard to recruitment/agency/temporary workers we use only specified, reputable employment agencies to source labour. Our performance indicator in this regard is via our HR team who ensure a right to work within the UK is part of this process.

Training

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 licensees and operators are also provided with access to eLearning modules on modern slavery via our eLearning provider.

Approval

The Executive Directors of Admiral Taverns have approved this statement and Modern Slavery Policy on 14th March 2022 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