Modern Slavery Statement

Modern Slavery Statement

Introduction

This statement sets out the steps taken by AT Brady Holdings Limited, (company registration number 10935683), (together with its subsidiaries, “Admiral Taverns”) to understand and mitigate the risk of modern slavery and human trafficking within its business and supply chains.

Admiral Taverns is an independent tenanted and leased pub company operating across England, Wales and Scotland and reports on a financial year running from 1^st June to 31^st May, and this statement relates to actions and activities in the financial year ending May 2026.

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), Admiral Taverns (Chester) Limited (company registration number 03989713), Admiral Taverns Piccadilly Limited (company registration number 07420758) and AT Brady Bidco Limited (company registration number 10935753).

As part of the hospitality sector, Admiral Taverns recognises its responsibility to take a robust approach to preventing modern slavery and human trafficking. We remain committed to acting responsibly and upholding high standards across our business and supply chains.

Organisational structure, business and supply chains

Admiral Taverns is an independent community pub company operating across the UK and headquartered in Chester. We own and manage circa 1,300 leased, tenanted and operator managed, known as Proper Pubs. We continue to invest in our pub portfolio through our capital investment programs and in supporting our people and licensees.

Our approach has received industry recognition, including Proper Pubs being named Best Community Pub Operator of the Year in 2024, then being a finalist in the same category in 2025, and with our CEO, Chris Jowsey, awarded Business Leader of the Year in 2025. These are alongside our prior awards of 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.

We also continue to demonstrate strong performance in our relationships with licensees. In 2025, Proper Pubs also introduced its first Awards Gala to recognise the contribution and achievements of its operators. Also in 2026 Pubs Code Adjudicator (PCA) Annual Tied Tenant Survey, Admiral Taverns achieved the highest overall satisfaction scores (72%), reflecting our focus on fair, transparent and supportive partnerships across our estate.

Being UK focused and community centric, Admiral Taverns considers its risk of slavery and human trafficking to be low. However, we recognise that modern slavery can occur in any sector and therefore continue to take proportionate steps to identify, assess and mitigate risks within both our operations and supply chains. 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 confirm that 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 should any concerns arise. Our BDM’s have a manageable number of pubs within their geographical remit to ensure that they maintain regular and effective contact with each pub. Any concerns relating to suspected illegal activity or potential breaches are expected to be reported and escalated in line with our company procedures.

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 support statutory compliance testing via our approved suppliers. Admiral Taverns’ suppliers and contractors range from large drinks manufacturing companies to professional advisers and agents, as well as regional and local contractors who provide services to Admiral Taverns pubs. Admiral Taverns conducts due diligence on new suppliers to our business. We adopt a risk-based approach to supplier due diligence, including onboarding checks and, where appropriate, ongoing monitoring, particularly for higher-risk services and supply chains, such as subcontracted services including facilities management and property works.

The vast majority of our suppliers and contractors are based in the British Isles. Admiral Taverns engages with them, with the expectation that they uphold the same high standards in relation to modern slavery.

Given the nature of our business and the suppliers that we deal with, we consider the risk of non-compliance to be low; however, we remain vigilant to potential risks. We believe the area of most risk in relation to modern slavery and human trafficking arises from 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 outside of our direct oversight and control. We will continue to mitigate this by raising awareness of modern slavery among our licensees through our contractual arrangements, which require compliance with all relevant UK legislation.

Responsibility for our anti-slavery initiatives is as follows:

Policies:

• Admiral Taverns operates the following policies to support our approach to identifying modern slavery risks and to prevent slavery and human trafficking within our business and supply chains:
• Modern Slavery Policy that operates alongside this statement and is available to employees. Admiral Taverns ensures awareness of this policy internally through its Human Resources team and Compliance Committee. We encourage all individuals 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 Officer. The statement and policy are reviewed in conjunction with relevant business areas and are reviewed regularly and approved by the Operating Board of Admiral Taverns, as required.
• Whistleblowing Policy We encourage all our workers, licensees, operators, suppliers and other business partners to report any concerns related to the direct activities, or the supply chains of, our business. Our whistleblowing procedure is designed to make it easy for individuals to make disclosures, without fear of retaliation. This includes concerns relating to modern slavery, unethical conduct, and inappropriate behaviour, including sexual harassment, in line with current legal requirements and our commitment to providing a safe and respectful environment.
• Anti Bribery Policy Our policy makes clear to employees the actions and behaviour expected of them when representing our business and managing its supply chain and procurement activities.
• Recruitment Policy We use only reputable employment agencies to source labour and undertake checks to verify their practices and ways of working.
• We have several other policies that protect our employees including our Employee Privacy Policy, Equality Diversity & Inclusion Policy, Anti-Harassment and Bullying Policy, Grievance Policy and Disciplinary Procedure.
• Our policies are developed in connection with relevant business areas and are reviewed regularly by the Compliance Committee and approved by the Operating Board of Admiral Taverns. All Policies are made available to employees at all times through our policy platform.

Risk Assessment:

• Risks are considered and discussed at the Compliance Committee and with any relevant members of the Operating Board. Modern slavery risks are assessed on a proportionate basis, taking into account the nature of our business, supply chains and our operational model.

Investigations/due diligence/performance indicators:

• We have had no known or suspected instances of slavery and human trafficking. We measure the effectiveness of our approach through a combination of policy acknowledgement, supplier compliance processes, including confirmations obtained through our tender and procurement frameworks. Any concerns should be raised to management level and the Compliance Officer and will be investigated in accordance with our established procedures and overseen by the Compliance Committee.
• Admiral Taverns operates and is often recognised for its openness and adherence to the Pubs Code Regulations. 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 and temporary workers within our direct workforce, we use only reputable employment agencies where required and undertake appropriate checks to ensure a legal right to work in the UK. Our HR team provides oversight of these processes as part of our recruitment controls.
• We provide our Modern Slavery Policy and statement to our suppliers through the Property and Commercial functions.
• Within our property function, suppliers are required to confirm their understanding of, and commitment to, our Modern Slavery statement through our Tender Document Framework. We are clear serious breaches of our Framework Agreement may result in the termination of the business relationship.

Training:

• We provide our Modern Slavery Policy and Statement to employees, and our Modern slavery Statement to relevant suppliers to support awareness of and response to slavery and human trafficking risks.
• We raise awareness of modern slavery through our policy and statement which are issued internally. As a performance indicator, employees are required to confirm that they have read and understood the documents. Guidance is also provided on identifying concerns, escalating issues and requesting further training. Employees are also given access to Modern Slavery training via our approved eLearning provider.
• We also provide as a resource to employees Government approved booklets on Modern Slavery, including Modern Slavery Awareness, and Transparency in Supply Chains a Practical Guide.
• Operators within our Proper Pubs operator-managed division are provided with access to modern slavery eLearning modules via our approved eLearning provider.
• We also make eLearning modules on Modern Slavery, provided through our approved eLearning provider, available for leased and tenanted licensees to purchase. These modules are provided free of charge under certain agreement types.

Approval

The Executive Directors of Admiral Taverns have approved this Modern Slavery Statement and our Modern Slavery Policy and are committed to ensuring there is no form of modern slavery within our business. We will review this statement annually and continue to strengthen our approach to identifying and addressing modern slavery risks, recognizing the importance of continuous improvement. We will continue to work to enhance knowledge and engagement in our processes in this regard.

Signed by Board Member/Executive Director:

Andrew Clifford

Property and Strategy Director

Date: October 2026