Our policy’s purpose
This statement relates to the financial year ended 31 December 2025 and has been produced in accordance with the Modern Slavery Act 2015 and sets out the actions that Birkdale (the Company) has taken to understand potential modern slavery risks related to its business activities and supply chains. This statement relates to actions and activities during the financial year.

The Company is committed to preventing modern slavery in its business activities and its supply chains and detailed below are actions that have been implemented, and will continue to be, with the aim of fulfilling this commitment.

Our commitments
We are committed to the prevention of modern slavery which includes servitude, forced labour, human trafficking and child slavery. Our Modern Slavery policy is delivered through a range of associated policies and procedures:

• Ethical Code of Conduct Policy
• Environmental Policy
• Corporate Responsibility Policy
• Whistleblowing Policy

Ultimate responsibility for ensuring prevention of modern slavery and for monitoring compliance to this modern slavery policy is held by John Abernethie, Founder.

The responsibility for monitoring of compliance including employee salary, employment rights and supply chain compliance is that of John Abernethie, Founder.

The Company recognises its obligations under the Modern Slavery Act 2015. This statement is made in accordance with Section 54 of the Act and outlines the steps taken during the financial year to prevent modern slavery and human trafficking in our business and supply chains.

The key direct risks of Modern Slavery to the Company are:

• No contracts of employment including zero hours contracts.
• Under pay of employees, self-employed contractors and subcontract companies – not paying as a minimum the living wage and not paying an appropriate market rate for services engaged.
• Excessive working hours – the majority of our direct employees have signed Working Time Opt Out Agreements. It is noted that this can lead in some organisations to excessive working hours, defined as, in line with NHS policy as greater than 56 hours per week, or not providing suitable rest periods between shifts or as a minimum a day off per fortnight.
• Not been entitled to work in the country of employment.
• Poor physical working conditions, including safety conditions.
• Bullying, discrimination and harassment.
The Company operates primarily within the UK and sources products from a range of suppliers, including overseas manufacturers.

Due Diligence
We shall ensure that:

• Individuals have the right to work in the country of employment.
• as a minimum a Living Wage is paid.
• that pay reflects current market values for the sector and role.
• that working hours restrictions are complied with, and excessive working hours discouraged.
• that bullying, discrimination and harassment is not permitted or tolerated in any form.
• that site conditions are safe and provide a working environment conducive to the protection of the environment, human health and quality workmanship.
• While the Company operates a relatively simple supply chain, we recognise that modern slavery risks may arise and we take proportionate steps to assess and manage those risks. We do not sub-contract work. We will however implement due diligence in our supply chain in relation to modern slavery:
o We will issue supplier questionnaires to all our key suppliers to enable us to undertake compliance checks to our requirements and to legal requirements regards modern slavery.
• Our contractual requirements require adherence to the Modern Slavery Act 2015.
• We expect our customers to deliver the same ethical treatment of us as a supplier, particularly in regards to payment terms and conditions, rates of pay and timely payment of applications.

Staff Training
We will provide all management staff training in relation to modern slavery.

Corrective Actions and Additional Comments

• Ensure slavery and human trafficking are considered and addressed in our approach to corporate social responsibility.
• Provide a safe channel for concerns about slavery or human trafficking to be raised through our Whistleblowing Procedure.
• Carry out regular audits to ensure all employees are paid at least the National Minimum Wage and have the right to work in the UK.
• Include obligations in all commercial agreements requiring suppliers (and their suppliers/sub-contractors) to operate in accordance with the Modern Slavery Act 2015.
• Appoint a named individual to oversee compliance with the Modern Slavery Act 2015 (currently: John Abernethie).
• Identify and address any areas of high risk in our supply chain.
• Provide training for all employees involved in the supply chain on issues relating to slavery and human trafficking.

While the Company may not meet all statutory thresholds for mandatory reporting, it has chosen to adopt the principles of the Modern Slavery Act 2015 and publish this statement voluntarily.

This statement is published on the Company’s website in accordance with Section 54 of the Modern Slavery Act 2015.
Board Approval: This statement was approved by the Board of Directors of Birkdale Sales Ltd on 15th June 2026.
Approved by the Board and signed on its behalf by:

John Abernethie, Director
Date Signed: 15th June 2026