This is the modern slavery and human trafficking statement of Brookhouse. This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (the ‘Act’) and applies to all our wholly owned subsidiaries and those joint ventures managed by us as their current respective slavery and human trafficking statement.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

ORGANISATIONAL STRUCTURE

Brookhouse has an extensive property portfolio that covers more than 1.7 million sq. ft. of space and spans across residential, retail and commercial sectors. With origins dating back to the 1930s, Brookhouse has developed an extensive network of retail partners, creating a portfolio of which 750,000 sq. ft. is food retail space.

As a group Brookhouse operates through wholly owned subsidiaries and joint ventures. In the majority of these arrangements, we provide asset management, property development and corporate services. Brookhouse managed joint ventures operate in line with its various compliance policies.

Brookhouse’s real estate portfolio is located entirely in the UK. We believe that our own employees are at low risk of modern slavery and human trafficking as the workforce consists primarily of office-based professional skilled labour. We consider our most significant risk areas to be in our supply chain.

OUR SUPPLY CHAINS

Our supply chains relate to our property development and investment business and encompass personnel, goods and services to support our property business. We source a wide range of goods and services, and our suppliers cover an extensive range of manufacturers, construction companies, material suppliers and professional service providers. The vast majority of our suppliers are based in the United Kingdom.

COMMITMENT

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in an part of our business. In light of the obligation to report on measures to ensure that all parts of our business and supply chains are slavery free, we will ensure background checks at recruitment for internal employment and review all commercial
appointments through our contractor assurance processes to ensure our supply chains are fulfilling their responsibilities.

We will undertake all practical steps to ensure that our standards are being implemented throughout our own business dealings and those of our supply chains whilst ensuring that all relevant legislation and regulations are complied with. We will only employ and trade with those who comply with this Policy.

Our aim is to identify and eradicate any form of slavery and human trafficking taking place in our business.

DUE DILIGENCE PROCESSES FOR MODERN SLAVERY AND HUMAN TRAFFICKING

We intend to build on the procedures from previous years and continue to review our supplier due diligence processes in relation to slavery and human trafficking. We will review our procurement processes in order to ensure that all of our existing and new suppliers are asked to confirm that they comply with the requirements of the Act. This will ensure that all organisations working with or on behalf of Brookhouse comply with all obligations they may have under the Act.

We will continue to review and assess the nature and extent of our exposure to the risks of slavery and human trafficking.

We will, where appropriate, communicate to potential key suppliers our zero-tolerance policy regarding slavery and human trafficking.

TRAINING

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, employee awareness training on slavery and human trafficking is provided to Brookhouse’s employees, emphasising the potential risks and the requirements of our staff and our supply chains to operate in accordance with our standards and in compliance with the relevant provisions of the Act.

As part of their induction, all new employees will be made aware of this modern slavery and human trafficking statement and the standards we expect.

This statement, as updated, has been considered and approved by the Brookhouse Board of Directors.

Reviewed by Andrew Gardner, Finance Director

March 2025