Anti Slavery Statement

Modern Slavery and Human Trafficking Statement

Introduction from Stuart Urquhart, Operations Director

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continue to develop our anti-slavery policies, reflecting 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 are not taking place anywhere in our supply chains.

Organisation's structure and business

We are Speymalt Whisky Distributors Ltd (t/a Gordon & MacPhail), a family-owned premium spirits business based in Speyside in the North East of Scotland, established in 1895. Our business is a retailer, wholesaler, and premium spirits producer.

Our head office, bottling, distribution and retail operations run from two sites in Elgin. We own and operate two distilleries: Benromach (in Forres) and The Cairn (in Grantown-on-Spey), both of which include visitor centres. The business currently has approximately 160 colleagues, all based in the UK.

Our supply chains

Our Supply Chain comprises suppliers from across the world. Spirits packaging (such as wooden boxes, glass bottles and corks) is purchased domestically in the UK and from China, France, Germany, Austria, Portugal and Mexico. Oak casks are imported from America, Portugal and Spain for whisky maturation. Production raw materials, such as malted barley, are purchased from companies based in the UK (where the barley is grown and produced within the UK).

As part of our initiative to identify and mitigate risk, we routinely visit and review our supply base. Our procurement policy sets out due diligence requirements for working with our suppliers. These include site visits prior to commencing any major new supply arrangement and regular review meetings in order to maintain strong working relationships and ensure transparency on working practices.

We acknowledge there is a heightened risk of human trafficking and modern slavery in certain countries and sectors around the world. Based on our current due diligence and supplier assessments, we consider the risk within our direct supplier base to be low; however, we recognise that no supply chain is risk-free and we remain committed to identifying, addressing and remediating any instances of exploitation should they arise. We continue to routinely visit and audit key suppliers.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our commitment is reflected in our colleague procedures, code of conduct and anti-slavery policies, which support our aim of acting ethically and with integrity in all our business relationships. We will continue to implement and enforce effective systems and controls to ensure that slavery and human trafficking are not taking place anywhere in our supply chains.

Supplier adherence to our values and ethics

To ensure all those in our supply chain and our contractors comply with our values, we are continuing to develop a robust supply chain compliance programme. We have expanded our procurement team to increase resources dedicated to maintaining routine supplier reviews. This work involves representatives from key business areas and is supported by a supplier code of conduct, which sets out our expectations of suppliers in relation to ethical standards, including labour and human rights.

Training

At present, we do not offer colleagues specific training on modern slavery and human trafficking. However, this training requirement is under active review. Over the coming year, we will introduce targeted training to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and in our business. We will keep the scope and effectiveness of this training under regular review.

Our effectiveness in combating slavery and human trafficking

Through our supplier review meetings and audits, we continue to develop key performance indicators (KPIs) to measure how effective we have been in ensuring that slavery and human trafficking are not taking place in any part of our business or supply chains. We will review and refine these measures over time to improve our approach.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 28 February 2025.

Signed,

Stuart Urquhart

Director

For and on behalf of Speymalt Whisky Distributors Ltd (t/a Gordon & MacPhail)

Date: 15/01/2026