The company talks about monitoring but not explicitly auditing or site visits.

pg. 5

"Current and proposed due diligence processes for modern slavery and human trafficking

Our supplier terms and conditions require compliance with the Modern Slavery Act and we expect all major suppliers to have suitable anti-slavery and human trafficking policies and processes in place. We anticipate working with Slave Free Alliance to improve our due diligence processes to enable us to identify and assess potential risk areas in our business and our supply chain.

By running many of our pubs as managed houses we have optimum control of the work environment, including labour scheduling and pay rates, thus reducing the risks within our own business. We recognise however that no business can be risk free. We are already engaging with employees to raise awareness through live webinars available to all employees on transatlantic slavery and modern slavery with recordings and additional spotlight videos available on the online training platform. We are also looking to increase awareness of the routes available to employees to raise concerns about any slavery-related issues. More detailed training is likely to form part of our new strategy on modern slavery.

Our effectiveness in combating slavery and human trafficking

We understand that the risks of modern slavery and human trafficking are growing, and we will continue to monitor our approach to mitigating this risk in the year ahead. With the help of Slave Free Alliance we will work to develop a more comprehensive long term strategy for dealing with modern slavery risks both within our business and in our supply chain."