SLAVERY AND HUMAN TRAFFICKING STATEMENT

Introduction 

Slavery and human trafficking remain a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. We are committed to preventing modern slavery in our supply chains; Colleagues are expected to report concerns and our leadership team are expected to act upon them. We are not aware of any instances of modern slavery in our supply chain.

Organisation's Structure

Scottish Leather Group Limited, and its subsidiary operating company Scottish Leather Group Operations Limited is a manufacturer of sustainable, luxury leather, and includes the brands Bridge of Weir Leather and Muirhead. The group has its head office and manufacturing operations in the UK. The group has an annual turnover in excess of £100M.

Our Business Policy

We have zero tolerance for slavery and human trafficking, and this is reflected in our Anti-Slavery and Human Trafficking Policy. We expect all contractors and those in our supply chain to comply with our values. All deparment leaders are responsible for compliance in their respective areas of responsibility and for their supplier relationships.

Due Diligence

We have taken the following steps to ensure that slavery, human trafficking and exploitation is prevented from taking place in our business and supply chains:

• We are a member of the Supplier Ethical Data Exchange (SEDEX), a membership organisation which support reasonable and sustainable business practices.

• We conduct a supplier approval process for our external contractors and suppliers and ensure they sign up to our Code of Conduct.

• We are a corporate partner of Scotland Against Modern Slavery (SAMS).

• We conduct pre-employment checks including verifying identities and establishing right to work.

• We include training to relevant members of staff which includes the observation of the signs of suspicious or non-ethical behaviours (including signs of modern slavery and identifying victims of trafficking), bribery, anti-competitive practices, and whistleblowing.

Our Effectiveness in Combating Slavery and Human Trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains, in accordance with our commitment to the standards required by UNGC:

• Completion of business unit audits by directors and senior managers.

• Use of labour monitoring and payroll systems.

• Level of communication and personal contact with the next link in the supply chains and their understanding of, and compliance with, our expectations.

• Our Supplier Code of Conduct, explicitly referring to standards of employment, ethics, working conditions and modern slavery has been issued (UK and internationally) for signatory approval by the entire supply chain.

• Specific audits are conducted in areas of priority and identified risk, with further planned for ongoing diligence and scrutiny.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group’s slavery and human trafficking statement for financial year ending 31st March 2026.

Mark Cowan
HR Director
Scottish Leather Group 
1st April 2025

CONFLICT MINERAL POLICY STATEMENT

Background

Scottish Leather Group Operations Limited does not use Conflict Minerals in the production of its leather. There are global concerns that proceeds from the mining, trade and sale of conflict minerals (tin, tantalum, tungsten and gold) are being used to directly or indirectly finance armed conflict and violence in the Democratic Republic of Congo and several adjoining countries (the “DRC Region”).¹ In an effort to curb the violence, a portion of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) required the Securities and Exchange Commission (”SEC”) to issue rules relating to the use of conflict minerals or “3TG” within manufactured products. In August 2012, the SEC issued a final rule implementing the “conflict minerals” disclosure requirements of the Dodd-Frank Act (the “SEC Conflict Minerals Reporting Rule”). If an SEC registrant manufactures (or contracts to manufacture) commercial products containing “3TG” that are necessary to the products’ functionality or production, the Rule requires that company to determine the origin and status of those minerals.²

Our Commitment

Scottish Leather Group Operations Limited is committed to conducting its business worldwide with respect for human rights and in compliance with all applicable laws, as evidenced by Our Vision, Mission and Values. To that end, Scottish Leather Group Operations Limited is taking steps to determine the origin of any 3TG that may be necessary to its products’ functionality or production.³ Scottish Leather Group will work closely with its supply chain partners and will seek, over time, to identify, reduce and eliminate the use in its products of conflict minerals that originate in the DRC Region and support armed conflict or violence.

Our Expectations

Scottish Leather Group Operations Limited expects its suppliers to partner it to comply with the reporting requirements set forth in the SEC Conflict Minerals Reporting Rule. Specifically, Scottish Leather Group Operations Limited expects that its suppliers will:

1. Work with their own upstream suppliers to identify the chain of custody for any conflict minerals (including the smelter, country of origin, mine location and status of any conflict minerals that may be present);
   
   
2. Cooperate with Scottish Leather Group Operations Limited in connection with any due diligence (or additional due diligence) that Scottish Leather Group Operations Limited chooses to perform with respect to its country of origin inquiries;
   
   
3. Provide, upon request by Scottish Leather Group Operations Limited, reasonable proof of the due diligence performed by the supplier to support any country of origin/sourcing certification provided to Scottish Leather Group; and
   
   
4. As needed, assist Scottish Leather Group to identify opportunities to source DRC conflict mineral-free materials.

 ¹ ”Conflict Minerals” or “3TG” are defined in Section 1502 of the Dodd-Frank Act as columbite-tantalite (the ore from which tantalum is derived), cassiterite (the ore from which tin is derived), wolframite (the ore from which tungsten is derived) and gold.

² Specifically, companies must determine whether: (i) any “conflict minerals” that are necessary to the functionality or production of a product originated in the covered countries; and (ii) whether the minerals directly or indirectly finance or benefit armed groups in the covered countries.

³ The due diligence process being followed by Scottish Leather Group Operations Limited is in material conformance with the current edition of the Organisation for Economic Cooperation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and accompanying supplements.