UK Modern Slavery Act & California Transparency Act - Transparency Statement, 2023


It is a priority for William Grant & Sons to ensure that the Company trades ethically, sources responsibly and works to prevent modern slavery throughout its organisation and supply chain. This statement highlights the Company’s key activities in this area and is made on behalf of William Grant & Sons and its subsidiaries.



William Grant & Sons is a family business with a diverse portfolio of brands. The Company operates within a global supply chain and sources raw materials for the manufacture of its products and for the marketing, distribution, and sale of these to customers and consumers. The Company is guided by a strong belief in morals and business ethics. The Company operates and complies with local laws and expects its suppliers to do the same.



William Grant & Sons has policies in place which ensure that the Company will not tolerate modern slavery in its organisation or supply chain. These policies include:

- The Ethical Sourcing Policy, which sets out the behaviour expected of potential or current suppliers. It includes the Company’s Supplier Code of Conduct which requires the human rights of employees to be respected and for suppliers to take appropriate steps to identify and eradicate modern slavery in all forms.

- The Code of Ethics, which requires employees to work fairly and with integrity. It references many of the Company’s core policies, including the Anti-Bribery and Corruption Policy and the Know Your Business Partner Policy, and requires employees to comply with these policies.

- The Anti-Bribery and Corruption Policy and the Know Your Business Partner Policy, which requires employees to conduct due diligence on third parties or individuals prior to the Company engaging with their services.

 The HR Policies and Processes, which ensure that employees are treated fairly in terms of:

- Pay and benefits

- Health & safety, working environment and conditions

- Treatment in the workplace

- Diversity, equity and inclusion

- The ability to speak up confidentially if issues arise

- Access to clear written terms of employment

- Clear expectations and processes with partner recruitment agencies for temporary staff.

- Recruitment processes which ensure that all employee candidates provide their right to work documentation and satisfy internal employment screening requirements

- The Speak Up Policy, which gives access to the Company’s confidential whistleblowing facility. This is available to all employees should they need to report discreetly a concern about illegal, dangerous, or inappropriate behaviour, including modern slavery.


Due diligence

In addition to the above policies, the Company has dedicated functions and processes which ensure that William Grant & Sons is not working with business partners or individuals who do not share the Company’s values. These include:

- A global procurement team who is responsible for assessing direct suppliers.

- A global legal compliance team who ensure that employees adhere to the Anti Bribery and Corruption Policy and the Know Your Business Partner requirements when working with third parties.

- Visits by the Company’s commercial teams to key distribution partners to understand their supply chains.

- Risk matrices and external management tools to assess and manage geographic and industry risks

- Membership of the Supplier Ethical Data Exchange (Sedex) which enables the Company to assess the ethical risks in its supply chain.

- Adherence to the UK’s HMRC and Irish Revenue Department requirements, which includes supply chain due diligence

- Regular audits by a variety of third parties, including ISO, the British Retail Consortium and large retail customers, which provide external verification that the Company is operating to the high standards expected of it, including modern slavery prevention.

- William Grant & Sons reserves the right to terminate relationships with organisations or individuals who do not meet its requirements or share its values.


Staff training

William Grant & Sons has mandatory e-learning training for all employees on its Code of Ethics. The training enforces the importance of conducting business with integrity and requires employees to comply with key policies, such as the Anti Bribery and Corruption Policy, the Ethical Sourcing Policy and the Know Your Business Partner Policy. All employees are assessed as part of this programme and asked to sign an annual declaration of compliance, confirming that they have complied with the Company’s Code of Ethics.


Assessing the risk and recent developments

The Company recognises that there is a risk of modern slavery in its supply chain given the industry and jurisdictions in which it operates. The Company is committed to mitigating this risk. Since the publication of its last statement on modern slavery, the Company has developed its Supplier Code of Conduct and Employee Code of Ethics to further ensure that business is conducted with integrity. The Company has also established a Modern Slavery Working Group to review and evaluate the effectiveness of the actions it is taking.



Where instances of potential modern slavery risks are identified they will be escalated to the Global Procurement team and the Global HR team.


This statement constitutes the modern slavery statement for the financial year ending 31 December 2022. In support of the UK Government’s mission for transparency within supply chains the Company has voluntarily published its statement on the Modern Slavery Statement Registry.


Glenn Gordon


7 September 2023