Comply with law and policies: Section 3, Supply Chain, Policy: There is no mention of compliance with the law, but there is a sourcing policy which outlines the standards Whitbread requires from all suppliers. These policies align with the International Labour Organisation and the UN Guiding Principles on Business and Human Rights – specifically, with regard to modern slavery. The policies state that there will be no: ‘Trafficked individuals working in any part of the supply chain, Forced, bonded, indentured or involuntary prison labour, Payment of recruitment fees on behalf of the worker.’ It is not mentioned whether this applies beyond direct suppliers.

Prohibit use of forced labour: Section 3, Subsection 3, International Business: There exists 'a set of baseline standards that Whitbread partners and franchisees will need to commit to implementing with regard to human rights, including modern slavery and forced labour; and, guidance documents to support them meet those standards within their own business and geography.' This text only refers to partners and franchisees, and not to the entire supply chain.

Code of Conduct: Section 3, Supply Chain, Policy: Whitbread has a ‘Responsible Sourcing Policy’ which ‘outlines the standards [they] require [from] all suppliers. This is not explicitly a code of conduct, but these standards do pertain to addressing modern slavery.

Contract Clause on forced labour: Section 3, Supply Chain, Policy: It is implied that there are contract clauses on forced labour as Whitbread 'reserve the right to cease trading with suppliers who demonstrate a persistent disregard' to the Responsible Sourcing Policy. This policy states that there will be no 'Forced, bonded, indentured or involuntary prison labour.'

"Whitbread’s Responsible Sourcing Policy outlines the standards we require all suppliers, across all geographies, products and services, to comply with. Our Policy is aligned with theInternational Labour Organisation (ILO) convention and the UN Guiding Principles on Business and Human Rights. Specifically, with regard to modern slavery, it states that there will be no:

• Trafficked individuals working in any part of the supply chain

• Forced, bonded, indentured or involuntary prison labour

• Payment of recruitment fees on behalf of the worker"

p. 4

p.3-4 "Human Trafficking Policy – This is available and has been communicated to all employees. The following Policies are embedded throughout our organisation and support the mitigation of any risk that a team member may be subject to modern slavery. Speaking Out Policy - Outlines the process we follow when our employees raise a concern about wrongdoing, danger or breach of the Code of Conduct, or criminal activity such as human trafficking. The policy ensures that concerns raised are dealt with without fear of reprisal, can be raised anonymously and will be investigated in line with a robust and transparent procedure. Any such concern may be raised internally, or through our independent and confidential Speaking Out line, which is run through Hospitality Action, our employee assistance provider. Grievance Policy - Supports and provides guidance to employees and managers regarding any concerns raised by an employee, in relation to their work. This process encourages concerns to be raised informally in the...