Modern Slavery Statement 2026 – 2027

Our commitment

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps Bread Holdings Limited (“BHL”), including its relevant UK subsidiaries and Group companies, is taking to prevent modern slavery and human trafficking within our business and supply chains.

This statement covers Bread Holdings Limited, The Bread Factory (“TBF”) and GAIL’s Bakery and relates to the financial year 1 March 2026 to 28 February 2027.

Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. We recognise our responsibility to respect the rights and wellbeing of the people who work directly for us and those who work within our supply chains.

Across BHL, we are committed to acting ethically, with integrity and transparency, and to maintaining appropriate

1. Our Business & Supply Chain

Bread Holdings Limited is a manufacturer, wholesaler and retailer operating within the UK food and hospitality industry.

The Bread Factory operates bakery and production facilities in Hendon, two sites in Milton Keynes, Bath and Manchester, producing and baking bread, cakes, pastries and other products for GAIL’s Bakery, wholesale & Grocery customers.

GAIL’s Bakery operates approximately 200 bakeries across the UK and continues to expand its presence into new communities.

Across the Group, we employ a diverse workforce across our bakeries, production facilities and support functions.

BHL has an extensive supply chain and procures a significant range of goods and services each year. We work with suppliers, contractors and business partners across areas including:

  • food and ingredients;
  • packaging;
  • equipment and maintenance;
  • logistics and distribution;
  • cleaning and facilities;
  • recruitment and labour providers;
  • technology; and
  • professional and other business services.

Our suppliers and partners may themselves work with subcontractors and other suppliers.

Our direct supply chain is predominantly UK and European based. However, we recognise that some of the ingredients, products and materials used within our business may originate from, or pass through, global supply chains.

We recognise that the size and complexity of our operations and supply chain can create different levels of modern slavery risk and that we have a responsibility to understand and manage those risks.

2. Our Policies & Governance

BHL operates policies and procedures designed to support ethical employment practices and provide our people with mechanisms to raise concerns.

Across GAIL’s Bakery and The Bread Factory, relevant policies include:

  • Anti-Slavery and Human Trafficking;
  • Whistleblowing;
  • Recruitment and Selection;
  • Equality, Equal Opportunities and Dignity at Work;
  • Anti-Bribery and Corruption; and
  • Ethical Trading standards and practices.

Our policies are communicated to our teams through our internal systems, induction processes and learning platforms, where relevant.

We continue to review our policies and procedures and are working towards greater alignment across BHL to provide a consistent Group-wide approach.

Across BHL, we also operate controls designed to ensure that employees have the legal right to work in the UK and that our employment practices, pay and benefits comply with applicable legislation.

Employees are encouraged to raise concerns through their manager, People team or our whistleblowing arrangements. We are committed to ensuring concerns can be raised without fear of retaliation and are appropriately investigated.

3. Assessing & Managing Risk

We recognise that modern slavery risk can arise both within our own operations and within our extended supply chain.

Our assessment of risk considers factors including the nature of the work being undertaken, the use of temporary or agency labour, recruitment practices, geographical location and the nature and origin of goods and services being supplied.

Areas where we recognise there may be an increased potential exposure to modern slavery risk include:

  • labour-intensive food manufacturing and production;
  • temporary and agency labour;
  • recruitment and labour providers;
  • cleaning, facilities and other outsourced services;
  • logistics and distribution; and
  • ingredients, packaging and other goods sourced through extended or international supply chains.

We will continue to develop our approach to assessing these risks so that our resources and controls are focused on the areas of greatest potential exposure.

We recognise that identifying indicators or concerns does not necessarily mean modern slavery has occurred. Where a concern is identified, our priority will be to understand the circumstances, protect potentially affected individuals and take appropriate action.

4. Due Diligence & Supplier Controls

The Bread Factory operates a supplier approval process and maintains an approved supplier list.

As part of our ongoing development of our supplier standards, we are strengthening the consideration given to modern slavery and ethical employment practices within supplier onboarding and review.

Our supplier self-assessment questionnaire includes questions relating to modern slavery.

We expect suppliers and business partners to comply with applicable modern slavery and employment legislation and to maintain appropriate standards within their own businesses and supply chains.

As we develop our Group-wide approach, we will increasingly focus our due diligence on suppliers and categories that we identify as presenting a higher potential risk.

This will include consideration of:

  • suppliers’ own modern slavery policies and statements, where applicable;
  • employment and labour practices;
  • use of subcontractors and labour providers;
  • ethical trading standards;
  • mechanisms available to workers to raise concerns; and
  • actions taken by suppliers to manage modern slavery risks within their own supply chains.

Where concerns are identified, we will seek to investigate and understand the circumstances and require appropriate corrective action where necessary.

The identification of a concern would not automatically result in the termination of a supplier relationship. Our approach will consider the welfare of affected workers and whether appropriate remediation and improvements can be achieved.

5. Our People, Training & Awareness

Our people have an important role in helping us identify and respond to potential modern slavery risks.

Within The Bread Factory, we continue to provide relevant managers with awareness of the indicators of modern slavery and the actions they should take if they have concerns.

Modern slavery awareness also forms part of relevant employee induction activity, helping employees understand potential indicators and how concerns can be raised.

During the 2026–2027 financial year, we are strengthening our approach further.

Our priorities include:

  • ensuring key members of our People and Talent teams undertake Stronger Together training, either as initial training or refresher training;
  • continuing to build modern slavery awareness amongst relevant operational managers;
  • reviewing our supplier standards with an increased focus on modern slavery prevention and ethical employment;
  • increasing awareness of support and reporting routes through workplace communications and noticeboards; and
  • developing a more consistent Group-wide approach across GAIL’s Bakery and The Bread Factory.

We will continue to review where enhanced or specialist training would benefit colleagues working in roles with greater exposure to modern slavery risks, including People, Talent, Procurement and operational leadership.

6. Measuring Our Effectiveness

We recognise that the absence of reported cases alone is not an effective measure of whether our approach is working.

We therefore intend to develop our monitoring so that we can assess both the implementation and effectiveness of our controls.

Our measures will increasingly include:

  • completion of modern slavery awareness and relevant specialist training;
  • the proportion of priority suppliers completing relevant due diligence or self-assessment;
  • the number and proportion of higher-risk suppliers subject to enhanced review;
  • monitoring of relevant recruitment and labour providers;
  • concerns or potential indicators raised through our reporting channels;
  • investigations undertaken where potential indicators are identified; and
  • corrective actions identified and completed.

Where concerns are raised, our focus will be on ensuring they are appropriately investigated and, where necessary, escalated to relevant external agencies.

We will use the information gathered through these measures to identify areas where our controls, training or supplier management need to be strengthened.

Our Priorities Of The Year Ahead

During the remainder of the 2026–2027 financial year and into the following year, our priorities are to continue strengthening our Group-wide approach.

In particular, we will focus on:

Supplier risk – developing a more structured approach to identifying and reviewing suppliers and categories presenting greater modern slavery risk.

Training – increasing modern slavery awareness and ensuring colleagues in key roles have appropriate knowledge and training.

Group-wide consistency – further aligning policies, reporting mechanisms and controls across GAIL’s Bakery and The Bread Factory.

Measurement – developing clearer measures to assess whether our controls are being implemented and are effective.

Awareness – ensuring our employees understand how to recognise potential indicators of exploitation and how to raise a concern.

We recognise that managing modern slavery risk requires ongoing attention and continuous improvement. We will continue to review our approach as our business grows and our understanding of our supply chain develops.

Approval:

This is a combined Modern Slavery Statement for Bread Holdings Limited and the relevant UK Group companies covered by this statement, including The Bread Factory and GAIL’s Bakery.

This statement has been approved by the Board of Directors of Bread Holdings Limited on 30th September 2026 and signed on its behalf by:

Tom Molnar

CEO & Co-Founder