UK Modern Slavery and Human Trafficking Statement

Modern slavery is an international crime. It is a global issue that transcends age, gender, and ethnicities. It includes victims who have been brought from overseas and vulnerable people in the UK, who are forced to illegally work against their will across many different sectors such as agriculture, hospitability, construction, retail, and manufacturing.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. C. H. Guenther has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

This policy applies to all people working for us, or on our behalf in any capacity including external consultants, contractors, and business partners.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes C. H. Guenther’s slavery and human trafficking statement for the fiscal year ending 2026.

Our Structures and Supply Chain

1. H. Guenther is a manufacturer of high quality fresh and frozen bread-based products. We deliver every day on time and in full across the UK and Europe with seven sites in Europe, employing approximately 800 employees. Our aim is to create a dedicated workforce by fostering a culture of respect, recognition, inclusion, and collaboration based on the highest ethical values. Our supply chains include the sourcing of raw materials principally related to the provision of bread-based products.

Our Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

• Diversity and Equality Policy
• Recruitment policy
• Whistleblowing policy
• Code of Business Conduct.
• Employment
  • Market related pay and reward
  • Enhanced benefits package
• Agency Workers: The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

We expect all those in supply chain and contractors comply with our values.

Policy Compliance

1. You must ensure that you read, understand, and comply with this policy.
2. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3. You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
4. You are encouraged to raise any concerns about any issue or suspicion of modern slavery in any part of the Guenther Bakeries business or supplying businesses at the earliest possible stage. If you are unsure about whether an issue constitutes any of the various forms of modern slavery, you should still raise this with your manager.
5. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion of modern slavery or human trafficking.

Breaches of this Policy

1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
2. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Transparency in our Supply Chain

We recognise our firm is exposed to greater risk when dealing with its suppliers, particularly those who have operations/suppliers in other territories. The following measures to review and manage this risk are in place.

• Guenther Bakeries operates a supplier policy and maintains a supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that a particular organisation has never been convicted of offences relating to modern slavery (and we reserve the right to conduct on site audits which include a review of working conditions).
• We want to help our people to understand more about this growing issue and how to report any suspicions they may have, whether in business or personal context. We have highlighted the modernslavery.co.uk site to all our employees, which holds useful information on how to recognise different types of slavery, how to spot signs and provide details of a telephone helpline.

Looking Forward: Key Performance Indicators

Going forward, we aim to work towards:

• Developing an employee training module that will be undertaken by all C. H. Guenther Bakeries employees. This training will outline what modern slavery is, how to identify it and what individuals should do if they suspect there are any cases of slavery occurring. Completion of this training will form a compulsory part of our employee’s annual review and new starter induction process.
• Developing a procedure to monitor how our suppliers comply with our supplier Code of Conduct and how our employees comply with the Company procedure, to determine the effectiveness of the steps taken to ensure that slavery and human trafficking is not taking place.

Steve Berger
Chief Human Resources Officer and Senior Vice President, Corporate Services