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The company states that they will "continue to monitor and evaluate our action to counter modern slavery and human trafficking at Board level (by the Audit and Remuneration Committee)" in their MSA.

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Our 5 Corporate Values: Relationships, Spirit, Excellence, Independence and

Integrity

 An Anti-Bribery Policy

 A Fraud Policy

 A Code of Conduct for Members of Staff incorporating a Whistleblowing Policy

 A Sales Code of Conduct

 

Assessing Risk and Management:

 

The management of risk within Corney & Barrow falls under the scrutiny of the Audit and Remuneration Committee; modern slavery & human trafficking has therefore appeared as an

agenda item for the Committee and will continue to do so in the future. Responsibility for implementing the firm’s activities to counter modern slavery lies with the Group Commercial

Director. We are members of the Wine and Spirit Trade Association. We support their efforts to encourage member companies to develop relationships with their supply chains so

that information about modern slavery and human trafficking risks can be identified and appropriately shared. Action taken During the last financial year Corney & Barrow has taken the following action to detect and counter the risks of human trafficking and modern slavery taking place within our supply

chain:

 We have developed and published a Modern Slavery and Human Trafficking policy.

 We have reviewed and rationalised our supplier database, ensuring that the information that we hold on our suppliers is up to date and verified.

 We have registered with HM Revenue & Customs under the Alcohol Wholesale Registration Scheme, which helps to ensure that the wine that we offer for sale originates from verifiable sources.

 We have put in place a comprehensive, risk-based process to undertake due diligence on our supply chain.

 We have undertaken a risk assessment on our supply chain with regard to modern

slavery and human trafficking in order to identify those suppliers where these are at greatest risk of occurring. To do this we have examined the risks according to the country where our suppliers are based, such as Chile and Argentina, together with the sectors in which our business operates, such as shipping and haulage.

 We have prepared awareness information for all our members of staff to enable them

to understand what modern slavery is and to know what to do should they suspect

that it might be occurring.

Action to be taken over the coming year

 We will be asking entities within our supply chain to tell us what they are doing to combat modern slavery and human trafficking.

 We will be distributing the awareness information to our members of staff, particularly those responsible for developing and maintain relationships with our suppliers, and monitoring the effectiveness of its content.

 We will continue to monitor and evaluate our action to counter modern slavery and human trafficking at Board level (by the Audit and Remuneration Committee).