Anti-Slavery Policy

Introduction
Modern slavery is a crime and a violation of fundamental human rights. It takes many forms, including
slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve the
deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Burhill Group Ltd takes a zero-tolerance approach to modern slavery and human trafficking, and we are
committed to acting ethically and with integrity in all of our business dealings and relationships, as well as
implementing and enforcing effective systems and controls to ensure modern slavery does not exist
anywhere in our own business or in any of our supply chains.
We are also committed to ensuring transparency in our own operations and in our approach to combating modern slavery throughout our supply chains, in accordance with our disclosure obligations under the Modern Slavery Act 2015.
We expect the same high standards from all of our contractors, suppliers, and other business partners.
We will continue to include specific prohibitions against the use of forced, compulsory, or trafficked
labour, as well as anyone held in slavery or servitude, whether adults or children, in our contracting
processes, and we expect our suppliers to hold their own suppliers to the same high standards.
This policy applies to all individuals who work for us or on our behalf in any capacity, including employees
at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents,
contractors, external consultants, third-party representatives, and business partners.
This policy is not part of any employee’s employment contract, and we reserve the right to change it at any time.

Policy Responsibilities
Burhill Group Ltd is ultimately responsible for ensuring that this policy conforms with our legal and ethical
commitments, as well as that all people under our control abide by it.
Burhill Group Ltd is in charge of implementing this policy on a daily basis, monitoring its usage and
effectiveness, dealing with any questions about it, and reviewing internal control systems and processes
to ensure they are successful in combating modern slavery.
Management at all levels is responsible for ensuring that people reporting to them understand and comply with this policy, as well as that they get proper and ongoing training on it and the subject of modern slavery in supply chains.
You are welcome to comment on this policy and offer ways to improve it. Any comments, suggestions or
queries are encouraged and should be addressed to the Burhill Group Limited Company Secretary at the
Support Office.

Policy Compliance
You must read, understand, and enforce this policy. The prevention, identification, and reporting of
modern slavery in any element of our company or supply chains is the duty of everyone who works for us
or is under our authority.
You must refrain from engaging in any action that might lead to or imply a violation of this policy.
If you feel or suspect that a conflict with this policy has happened or will occur in the future, you must
contact your line manager or a business director as soon as possible.
You are urged to express concerns about any issue or suspicion of modern slavery in any aspect of our
business or any supplier tier’s supply chain as soon as possible.
If you feel or suspect a violation of this policy has occurred or may occur, you must alert your line manager or a company director as soon as possible, or report it in accordance with our Whistleblowing Policy.
You should note that where appropriate, and with the welfare and safety of local workers as a priority, we
will give support and guidance to our suppliers to help them address coercive, abusive and exploitative
work practices in their own business and supply chains.
If you have any doubts about whether a specific act, the treatment of employees in general, or their working circumstances inside any tier of our supply chains represents any of the numerous types of modern slavery, please contact your line manager or a company director.
We want to promote transparency and will assist anybody who expresses concerns in good faith under this policy even if those worries turn out to be incorrect. We are dedicated to ensuring that no one experiences any adverse treatment due to reporting in good faith their concern that modern slavery in any form is or may be occurring in any section of our own business or in any of our supplier networks.
If you suspect you have been subjected to such treatment, you should immediately notify your line
manager. If the problem is not resolved, and you are an employee, you should speak to the People Team
and file a formal complaint.

Communication & Awareness
Training on this policy, as well as the threat our company faces from modern slavery in its supply chains,
is part of the induction process for all new employees, and updates will be offered through established
channels of communication between the company and you.
Our zero-tolerance stance to modern slavery must be conveyed to all suppliers, contractors, and business
partners from the beginning of our commercial engagement with them and reinforced as needed
subsequently.

Policy Breaches
Any employee who violates this policy may face disciplinary action, which might result in dismissal for
misconduct. If other persons or organisations working on our behalf violate this policy, we reserve the right to terminate our relationship with them with immediate effect.
This policy includes all Burhill Group Limited’s subsidiaries which are Burhill Golf & Leisure Limited,
Shropshire County Leisure Limited, Burhill Developments Limited, Adventure Leisure Limited, Ninja
Leisure Limited, Ninja Leisure UK Sheffield Limited, Ninja Leisure UK Southampton Limited, Innovation
Leisure Manchester Limited.
This policy will be kept under review and amended as necessary.

Simon Thompson
Chief Executive Officer
September 2025