Slavery & Human Trafficking Statement

Slavery and Human Trafficking Statement made on behalf of Eastern Holdings Limited and its subsidiary companies further to the provisions of the UK Modern Slavery Act 2015

Slavery and Human Trafficking Statement made on behalf of Eastern Holdings Limited and its subsidiary companies further to the provisions of the UK Modern Slavery Act 2015

Statement by the Chairman of Eastern Holdings Limited

We are proud of the conditions of employment afforded to all our employees throughout Eastern Holdings Ltd and its subsidiary companies – EHL Group.

Whilst we operate in a sector generally considered to be lower risk, we recognise that no organisation is immune from modern slavery and human trafficking risks, particularly within extended supply chains. We therefore adopt a proportionate and risk-based approach to identifying and addressing potential exposure across our business and supply chain.

The employment and procurement practices operated by the businesses within EHL Group ensure we are rightly viewed as an excellent and supportive employer. When operating as a purchaser of goods or services, we expect a high level of ethical conduct from those organisations with which we do business within our supply chain.

Organisation’s Structure

EHL is the holding company for a property company and motor retailing businesses who are independent family owned, incorporated in Scotland, representing a number of franchised brands in the niche and premium sector. Our Head Office is located in Broxburn, West Lothian, and we operate from a number of sites with principal activities taking place within our Edinburgh Luxury Car Village at Newbridge.

The trading companies and franchised businesses within EHL Group are regulated by the FCA.

Trading Sites and Supply Chains

EHL Group’s principal activities are motor vehicle sales and servicing, the supply of replacement parts, the repair of accident damaged vehicles and the rental of properties. Representing 20 of the world’s top brands, we trade from thirty businesses geographically covering the central belt of Scotland to Dundee in the north and Coldstream in the Borders.

We recognise that certain areas of our supply chain, including facilities management, cleaning services, construction, parts supply and the use of agency labour, may present a higher inherent risk and therefore require additional oversight.

In respect of EHL’s supply chain, as part of our due diligence process, we use our reasonable endeavours to conduct risk assessments of the third parties we work with and investigate, where feasible.

We adopt a risk-based approach to supplier due diligence, including enhanced checks where suppliers operate in higher-risk sectors or geographies. This may include supplier questionnaires and contractual expectations relating to ethical standards.

As part of our risk assessments, we have procedures in place to identify whether there is a possible risk of slavery and human trafficking either in the business or our supply chain.

Where potential risks are identified, we work with suppliers to understand and address concerns where appropriate.

We also ensure that any labour providers and recruitment agencies engaged by the Group are reputable and operate in line with relevant legislation and expected standards.

We will continue to review our approach to ensure it remains proportionate and appropriate to the level of risk within our business and supply chain.

Anti-Slavery Policy Statement

EHL Group operates a zero tolerance policy in regard to slavery and human trafficking and is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

This Anti-Slavery Policy Statement is the principal articulation of EHL Group policy on slavery and human trafficking and is intended to inform and influence all operational procedures within our trading activities.

The stated Anti-Slavery Policy Statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking is not taking place anywhere in the business or related supply chains.

Due Diligence and Implementation

As part of our initiative to identify and mitigate risk, we operate a range of policies and procedures appropriate to the different companies within the EHL Group. These include:

• Employee Code of Conduct
• Management Training
• Recruitment Policy
• Equal Opportunities Policy
• Money Laundering Policy
• Bribery and Corruption Policy
• Whistleblowing Policy

EHL Group also articulates a series of employee rights and benefits available to employees via the employee intranet and individual contracts of employment.

Controls and Accountability

EHL operates a fully integrated reporting structure across its businesses, including an HR Department led by the Group HR Manager and an Internal Audit function led by the Motor Trade Finance Director, both of whom report to the Group Financial Director/Group Secretary.

Each operating division has a Managing Director who has reviewed and agreed to the terms of this statement. Departments and managers have clear reporting responsibilities to management and the Boards of companies within the EHL Group.

EHL Group engages the services of KPMG as external auditor and receives regular reports from both external and internal audit functions. These combined processes support the identification, assessment and monitoring of potential risk areas within our supply chains.

It should be noted that EHL Group operates in line with National Living Wage and National Minimum Wage regulations.

Reporting Concerns

We are committed to ensuring that all employees and third parties have access to safe and effective mechanisms to raise concerns. Our Whistleblowing Policy provides a confidential route to report suspected wrongdoing, including concerns relating to modern slavery, without fear of retaliation or detriment.

We recognise the importance of awareness in this area and ensure that relevant policies, including our Whistleblowing Policy and Code of Conduct, are accessible to all employees. These provide guidance on expected standards and how to raise concerns where required.

Legal and Regulatory Compliance

This statement is made with regard to the obligations arising under section 54(1) of the UK’s Modern Slavery Act 2015.

We seek to ensure that when entering into material contracts, our suppliers and contractors comply with our Anti-Slavery Policy, particularly during tender processes and supplier reviews.

Conclusion

Accordingly, this statement constitutes the Slavery and Human Trafficking Statement for the EHL Group and all its trading entities for the 2024/2025 financial year.

This statement was approved by the Board of Directors in May 2026 and will be reviewed annually.

Douglas J Brown
Chairman and Group Managing Director

Douglas J Brown
Chairman and Group Managing Director