Modern Slavery, Child Labour and Human Trafficking Statement

At GDK International Limited (the Company) we conduct our business with integrity, transparency and fairness. We are committed to the prevention of slavery, servitude, forced or compulsory labour, child labour and human trafficking in our business, in the businesses of those who represent our brand as franchise partners and in the business of those who supply goods or services to us. We procure goods and services in a sustainable and ethical manner in compliance with our values and relevant law and policy, including the Modern Slavery Act 2015. 

We do not accept slavery, human trafficking or the exploitation of children in our business. We expect all franchise partners, suppliers and business partners to meet these standards and reserve the right to investigate, require remediation, suspend or terminate relationships where concerns are identified and not appropriately addressed. 

Our business  

Scope of this Statement 

This statement applies to GDK International Limited and reflects our approach across our corporate operations, franchise network, supply chain and business partnerships. It covers our employees, franchise partners, suppliers, contractors and any third parties providing goods or services connected to our operations. 

The Company operates a franchise-led business model, working with a network of franchise partners across multiple jurisdictions. While this model supports growth and local market expertise, it also requires robust oversight to ensure that labour standards, ethical practices and compliance with applicable laws are consistently maintained across franchise operations and supply chains.  

The Company is headquartered in Scotland. The Company operates in several jurisdictions, including in the UK, Europe, Asia and North America.  

Our commitment on child labour 

The Company recognises that children are particularly vulnerable to exploitation and that child labour may be hidden within global supply chains. We are committed to taking reasonable and proportionate steps to prevent the use of child labour in connection with our operations, goods and services. 

For the purposes of this statement, the Company expects all suppliers, contractors and business partners to: 

• comply with applicable minimum age, compulsory schooling, wage, working time, health and safety and employment laws; 
• maintain reliable systems to verify the age and identity of workers;
• ensure that no worker is employed below the legal minimum age in the jurisdiction where the work is performed; 
• ensure that any young workers who are lawfully employed are protected from hazardous work, night work, excessive working hours and any work that may interfere with their education, health, safety or development; and ensure that recruitment fees are not charged to workers and that identity documents are not withheld. 

Risk Assessment 

We recognise that the risk of modern slavery and child labour may be higher in certain sectors and geographies. Within our business model, areas of potential higher risk include: 

• food supply chains and sourcing; 
• construction, refurbishment and fit-out activities; 
• cleaning, facilities management and security services; 
• logistics, warehousing and distribution; 
• the use of agency labour; and 
• operations in higher-risk jurisdictions. 

We continue to assess these risks and prioritise due diligence activities accordingly. 

Due diligence  

We maintain and regularly review a central register of suppliers and business partners. This review supports the identification of higher-risk relationships and informs our due diligence and monitoring approach. We use this review to prioritise due diligence activities and determine where enhanced scrutiny, engagement or intervention may be required. We will continuously collaborate with others to help ensure that slavery, human trafficking and child labour are not taking place in any part of our supply chain or our business.  

As part of our due diligence, the Company may take steps including: 

• assessing modern slavery and child labour risk by supplier or business partner category, geography, sector and service type; 
• requesting suppliers and business partners to confirm compliance with applicable anti-slavery and child labour laws and standards; 
• seeking information from suppliers and business partners about their own workforce, subcontracting arrangements, recruitment practices and age-verification processes; 
• requiring suppliers and business partners to notify the Company promptly if they identify any actual or suspected slavery, trafficking or child labour in their operations or supply chains; 
• reviewing and, where appropriate, updating supplier and business partner onboarding and approval processes to address modern slavery and child labour risks; and 
• considering whether enhanced due diligence, follow-up engagement, remediation measures or termination of the relationship are appropriate where concerns are identified. 

We expect franchise partners to adopt equivalent standards and may incorporate modern slavery compliance requirements into franchise agreements, supplier terms and onboarding processes. 

Reporting and remediation 

Any colleague, franchise partner, supplier, business partner or other stakeholder who becomes aware of actual or suspected slavery, human trafficking or child labour connected with the Company’s business is encouraged to report the matter promptly through appropriate internal channels.

Where concerns are raised, the Company will assess them promptly and proportionately, and determine what further investigation or action is appropriate. Where child labour is identified or reasonably suspected, the Company will consider the best interests, safety and welfare of the child when determining next steps. This may include requiring immediate protective action, engaging with the supplier and business partner on remediation, seeking evidence of corrective measures, and, where appropriate, suspending or terminating the relevant relationship. 

In all cases, we will seek to ensure that any action taken does not place affected individuals, particularly children or vulnerable workers, at greater risk. Where appropriate, we will consider specialist advice and remediation approaches aligned to best practice. 

Training & Awareness 

Relevant Company personnel are provided with access to this statement and receive training appropriate to their role, particularly those involved in procurement, supplier management, operations and franchise support. 

The Company will seek to ensure that relevant personnel involved in procurement, supplier management, operations and franchise support (marketing, finance, guest care, people) are aware of indicators of child labour risk, including: 

• lack of reliable proof of age; 
• workers who appear unusually young for the work being performed; 
• hazardous tasks being carried out by young workers; 
• excessive working hours or night working by young workers; 
• restricted movement, fearfulness, debt bondage or signs of coercion; and 
• the use of informal labour brokers or opaque subcontracting structures. 

Key Performance Indicators (“KPIs”) 

We use the following KPls to measure how effective we have been in seeking to ensure that slavery, human trafficking and child labour are not taking place in any part of our business or supply chains: 

• keeping a log of the number of colleagues who have confirmed that they have read and understood this statement;  
• recording the nature of and number of any anti-slavery or child labour concerns reported to the Company’s Chief Financial Officer or other designated internal contact;  
• recording the number of concerns assessed within a reasonable time of being reported and the time taken to conclude any follow-up investigation; 
• tracking the frequency and nature of follow-up communications, as appropriate, with relevant suppliers and business partners, or potential suppliers and business partners, in relation to slavery, human trafficking and child labour risk questionnaires or supplier onboarding processes; and 
• tracking the number of suppliers and business partners subject to enhanced due diligence, corrective action requests, remediation follow-up or disengagement for modern slavery or child labour concerns. 
• tracking completion of risk-based supplier reviews and the outcomes of any remediation actions. 

Culture and Ongoing Review 

We recognise the importance of developing a culture within the Company which does not tolerate slavery, human trafficking or the exploitation of children and is not complacent about the associated risks. Through our good business practices, we are committed to embedding and strengthening a culture that does not tolerate slavery, human trafficking or the exploitation of children. We will continue to take steps to embed and strengthen this culture across the brand through training, education and awareness initiatives.  

Governance 

Responsibility for overseeing this statement and the Company’s approach to modern slavery and child labour sits with senior leadership. Relevant functions, including Finance, People and operational teams, support the implementation of this approach through procurement, supplier management and business operations. 

Statement approval 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our modern slavery statement for the financial year ending 31st December 2025.  

Simon Wallis 

Chief Executive Officer 

GDK International Limited 

This statement will be reviewed annually and published on the Company’s website in accordance with the Modern Slavery Act 2015.