The North British Distillery Slavery and Human Trafficking Statement

Lothian Distillers Limited and its trading subsidiary The North British Distillery Company Limited (“the

Company”) are committed to preventing acts of modern slavery and human trafficking from occurring within

both its business and supply chain. In accordance with Section 54 of the Modern Slavery Act 2015, we set

out below the steps that have been taken by the Company during its financial year ended 31 December 2025

and any proposed steps for the financial year 1 January 2026 – 31 December 2026 to ensure that we strive

to prevent slavery and human trafficking in our business and our supply chain.

OUR BUSINESS AND SUPPLY CHAIN

The Company is a producer of Scotch Grain Whisky operating out of its distillery in Edinburgh, Scotland, with

its maturation site in Addiewell, Scotland, and works with a wide range of third party suppliers.

We have robust employment contracts, employment-related policies and procedures and recruitment

procedures in place which are updated regularly and no form of modern slavery will be tolerated within our

business. The Board adopted an Anti-Slavery and Human Trafficking Policy on 23 March 2016 which sets out

the Company’s commitment to acting ethically and with integrity in all our business relationships and to

implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not

taking place anywhere in our supply chains. Our Anti-Slavery and Human Trafficking Policy is available on

our website. The Board appointed its Finance Director as Compliance Manager with the responsibility for day-

to-day compliance with the Anti-Slavery and Human Trafficking Policy.

As part of the Company’s efforts to monitor and reduce the risk of slavery and human trafficking occurring

within our supply chain, we undertake the following due diligence procedures:

• All new suppliers and contractors are required to accept and commit adherence to our Anti-Slavery &

Human Trafficking Policy.

• All contractors are required to be accredited by our SSIP partner who independently audit and review

their Modern Slavery Policy Statement.

• Our contractual terms mandate a number of specific obligations on our supply partners in relation to

the Modern Slavery Act 2015 including imposing the same obligations on their own supplier chain.

• In relation to existing suppliers, a new risk-assessment protocol exercise has been developed taking

into account the physical location of the supplier and the nature of the goods/services supplied.

• During the next 12 months our risk-based assessment tool will be applied to all suppliers / contractors.

• Where any existing supplier is considered to fall into the category of high or medium risk as a result

of this assessment, the supplier will be required to complete and return a due diligence questionnaire

based on the UK Government Modern Slavery Assessment Tool (MAST).

• Suppliers / contractors who fail to accept our requirements will not be approved to supply goods or services to our business.

BOARD APPROVAL

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes The

North British Distillery Company Limited’s slavery and human trafficking statement for the financial year ended

31 December 2025. I confirm that this statement has been approved by our Board of Directors who will review

and update it annually.

Gavin Brogan

Managing Director