Modern Slavery Act
Modern Slavery and Human Trafficking Statement – Financial Year Ending 30 June 2026
Our Commitment
Finsbury Food Group is committed to trading ethically, sourcing responsibly and helping to prevent modern slavery and human trafficking across our organisation and supply chain. We continually review our practices, controls, and awareness to help identify, prevent and address labour exploitation.
Organisational Structure
Finsbury Food Group is a leading speciality bakery manufacturer serving both major multiple retailers and the foodservice channel. Our purpose is to bring bakery excellence to every meal. The Group has approximately 3,000 colleagues across eight UK manufacturing sites and one distribution centre, with annual turnover in excess of £450 million. During Financial Year 26, the Group progressed the integration of acquired businesses into its governance and compliance framework, with further alignment continuing during Financial Year 27.
Our Business
This statement covers Finsbury Food Group Limited and its UK subsidiaries and businesses:
- Memory Lane Cakes Limited
- Lightbody of Hamilton Limited
- Johnstone’s Food Service Limited
- Fletchers Bakeries Limited
- Nicholas and Harris Limited
- Ultrapharm Limited (UK entity only)
- Lees of Scotland Limited
- Flower & White Limited
Flower & White Limited was acquired during Financial Year 26 and is being integrated into the Group’s governance, compliance, training, reporting and supplier due-diligence arrangements.
Our Supply Chains
Our Procurement team sources from over 600 different suppliers. Most of our raw materials are sourced from suppliers based in the UK. In many cases, we have long-term strategic partnerships in place to help build effective, fair, and transparent supply chains. Our supply-chain due diligence focuses on raw materials, packaging, labour providers and selected outsourced services where worker vulnerability may be greater.
Actions and Progress During Financial Year 26
During Financial Year 26, the Group strengthened its approach to identifying, preventing and addressing modern slavery risks. The table summarises key activity and intended Financial Year 27 focus areas.
| Area | Financial Year 26 activity | Financial Year 27 intended focus |
|---|---|---|
| Supplier due diligence | Continued supplier engagement through SEDEX, building on the previously reported 88% increasing to 92% linkage. | During Financial Year 27, we intend to continue increasing supplier visibility through SEDEX. |
| Ethical audits | Maintained ethical audit arrangements across relevant UK entities. | During Financial Year 27, we intend to continue managing non-conformances through agreed close-out processes. |
| Labour providers | Continued oversight of agency labour providers and worker-welfare expectations. | During Financial Year 27, we intend to strengthen tendering, assurance and responsible recruitment requirements. |
| Training and awareness | Continued Stronger Together training for relevant colleagues and Anti-Slavery Day awareness activity. | During Financial Year 27, we intend to extend training and practical guidance to additional relevant roles. |
Our Policies on Slavery and Human Trafficking
We have the following policies in place that underpin our commitment and which we periodically review and update:
- Policy on Reporting of Incidents (Whistleblowing Policy)
- Equality, Diversity and Inclusion Policy
- Recruitment and Selection Policy
- Young Persons at Work Policy
- Human Rights Policy
Due Diligence Processes for Slavery and Human Trafficking
As part of our initiative to identify and mitigate risk, we monitor ethical standards across the business on a regular basis both internally and through external third-party audits. We are a member of the Supplier Ethical Data Exchange (SEDEX) and sites complete self-assessment questionnaires and undergo ethical trade audits at the required frequency.
Our Technical Conditions of Supply require our raw material and packaging suppliers to complete our Ethical Questionnaire, based on the ETI Base Code, and register with SEDEX, making their ethical data visible to us and enabling us to drive ethical standards within our supply chain. In our previous statement, directly 88% of relevant suppliers were reported as linked to us through SEDEX. During Financial Year 26, we continued to encourage relevant suppliers to register and link their ethical data, increasing supplier linkage to 92%. Further engagement is intended to continue during Financial Year 27.
Speaking Up, Responding to Concerns and Remediation
Colleagues and workers can raise concerns through an independent, free, anonymous and confidential external whistleblowing line, grievance procedures, People Team support and established colleague-engagement channels. Reports are monitored, investigated where appropriate, and reviewed through established governance processes, including the Operating Board. Where a potential modern slavery concern is identified, we will assess the circumstances, protect affected individuals, seek specialist advice where required, and support effective remediation.
Modern slavery is listed on the Corporate Risk Register and is reviewed through established governance processes, with oversight from the Technical and People functions. Accountability is shared across People, Technical, Procurement and Operations, covering worker welfare, training, reporting, supplier due diligence, ethical audit, SEDEX activity and site-level implementation.
Supplier Adherence
We do not tolerate modern slavery or human trafficking within our operations or supply chains. Where concerns are identified, we take proportionate action, prioritising worker safety and welfare.
Agency labour and outsourced services, including logistics, warehousing, cleaning and facilities services, are recognised as higher-risk areas and are subject to appropriate due diligence and monitoring. Labour providers are expected to demonstrate right-to-work compliance, responsible recruitment practices, worker-welfare controls and support for the Employer Pays Principle.
Training
We provide modern slavery and human trafficking training and awareness for relevant colleagues.
Relevant colleagues complete Right to Work checks, manage SEDEX and ethical audit activity, close non-conformances, and receive role-appropriate guidance on hidden labour exploitation.
Selected colleagues complete Stronger Together training, while relevant Purchasing colleagues undertake ethical trading training through CIPS where appropriate.
Resources from the Stronger Together campaign are available across the business and supported by the annual Anti-Slavery Day awareness activity.
Measuring Our Effectiveness
We monitor progress through audit outcomes, supplier visibility, training, labour-provider oversight, reporting arrangements and agreed improvement actions. During Financial Year 27, we intend to strengthen outcome-focused measures and establish reliable baseline data where required.
Further Steps
During Financial Year 27, we intend to focus on the following areas:
- Strengthening training and practical guidance for relevant roles.
- Enhancing assurance of labour providers and selected higher-risk outsourced services.
- Improving supplier visibility and risk-based due diligence.
- Developing clearer measures of progress and effectiveness, while continuing the integration of Flower & White within the Group framework.
Approval
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Finsbury Food Group’s slavery and human trafficking statement for the financial year ending 30 June 2026. This statement received Board approval on 26 August 2026.
John Duffy
Chief Executive Officer
Finsbury Food Group Limited