Modern Slavery Transparency Statement, 2026

William Grant & Sons Limited (“the Company”) is committed to trading ethically, sourcing responsibly, and preventing all forms of Modern Slavery - including forced labour, child labour, and human traﬀicking - within its operations and supply chains.

This statement outlines the actions taken by the Company during the financial year ending 2025 and is made on behalf of William Grant & Sons and its subsidiaries, as listed in Appendix 1.

ORGANISATIONAL STRUCTURE, BUSINESS AND SUPPLY CHAIN

William Grant & Sons is an independent, family-owned business operating across global markets. The Company sources raw materials and services through an international supply chain to support the manufacture, marketing, distribution, and sale of its products to customers and consumers. The Company is guided by a strong belief in morals and business ethics. It operates in compliance with applicable laws and regulations and expects its suppliers to uphold the same standards.

ASSESSMENT OF THE RISK OF MODERN SLAVERY

The Company recognises that there are inherent risks of Modern Slavery within its operations and supply chain given the geographic spread and nature of its activities. The Company is committed to reducing this risk to the lowest level practicable.

ACTIONS TAKEN TO ADDRESS RISKS OF MODERN SLAVERY

During the reporting period, the Company continued to strengthen its approach to managing modern slavery risks by embedding its existing policies and maintaining robust monitoring and due diligence processes.

a. Policies and Standards

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

The Procurement Policy and Supplier Code of Conduct, which set out expectations for ethical sourcing and require suppliers to respect human rights and address modern slavery risks within their operations.
The Code of Ethics, which requires employees to act with integrity, fairness and professionalism in all business dealings. It reinforces the Company’s commitment to ethical conduct and requires compliance with key policies and procedures, including the Global Anti-Bribery Policy and the Know Your Business Partner due diligence process.
The Global Anti-Bribery Policy and Know Your Business Partner due diligence process, which require appropriate risk-based due diligence to be conducted on third parties prior to engagement, helping the Company identify and manage potential modern slavery and other compliance risks. The Child Remediation Policy, which outlines the steps to be taken in the event that child labour is identified within the Company’s operations or supply chain.
HR policies and processes, which are designed to support the fair treatment of employees, through transparent recruitment practices, verification of right-to-work documentation, fair pay and working conditions, adherence to the Company’s Dignity at Work Charter, and appropriate oversight of third-party recruitment agencies.

All employees can also confidentially raise any issues under the Company’s Global Speak Up! Policy. The policy provides a range of reporting channels for illegal, dangerous, or inappropriate conduct, including modern slavery, with anonymous reporting available through EthicsPoint, an independently operated whistleblowing platform.

b. Supplier Due Diligence

The Company has implemented a range of measures to assess and monitor modern slavery risks within its supply chain. These include:

The Supplier Code of Conduct which sets out expectations relating to ethical sourcing and modern slavery risks, including requirements for suppliers to conduct due diligence within their own supply chains.
Compliance is supported through contractual commitments and acceptance of the Code is a condition of participation in WG&S’ tender processes.
Full membership and participation in the Supplier Ethical Data Exchange (“Sedex”) which enables the Company to evaluate both existing and prospective suppliers through self-assessment questionnaires and independent third-party audits. These assessments are reviewed regularly to identify potential risks. Where issues are identified, structured processes are in place to ensure timely and eﬀective remediation.
Applying a risk-based approach to the assessment and management of third-party relationships, taking into account geographic, sectoral, and operational factors. This is supported by dedicated internal functions including a global procurement team responsible for assessing direct suppliers, and a global legal team overseeing adherence to the Company's Global Anti-Bribery Policy and Know Your Business Partner due diligence requirements.
Use of risk matrices and external tools to assess geographic and industry risks, as well as ad hoc visits by the Company’s commercial teams to key distribution partners to understand their supply chains.

The Company requires its direct suppliers to comply with laws regarding slavery and human traﬀicking in the countries where they operate and reserves the right to terminate relationships with organisations or individuals who do not meet these standards.

c. Internal governance and Training

The Company promotes awareness of ethical business practices through its Code of Ethics training and communications.

Employees are required to:

Complete mandatory e-learning modules; and
Confirm compliance with all Company policies, including the Code of Ethics, through an annual declaration.

These measure support awareness of risks relating to ethical business conduct, including modern slavery.

d. Reporting

The Company maintains clear channels for reporting concerns relating to unethical conduct or potential modern slavery risks.

Concerns may be raised through

Line management, a member of the Company's Legal team, HR team or Executive Board; or
Confidential reporting channels under the Global Speak Up! Policy.

All reports are investigated and addressed in accordance with Company policies.

MEASURING EFFECTIVENESS

The Company measures the eﬀectiveness of its modern slavery framework through a combination of ongoing monitoring, supplier assessments and key performance indicators.

Supplier Risk Monitoring: The Company monitors suppliers through quarterly Sedex assessments, including self-assessments and, where applicable, Sedex audits, to identify and manage potential risks. One critical non-conformance was identified during the reporting period and was promptly investigated and remediated through engagement with the supplier.
Supplier Code of Conduct adoption: 95% of the Company’s direct suppliers have formally acknowledged the Supplier Code of Conduct. The Company continues to engage with the remaining suppliers to achieve full adoption and is also working with higher-risk indirect suppliers to encourage alignment with its standards.
Training and Awareness: Employee participation in compliance-related training is monitored through completion tracking, feedback mechanisms and knowledge assessments to help reinforce expectations regarding ethical business conduct.
Incident Reporting: The Company monitors the use of reporting channels to identify and respond to any modern slavery concerns. No instances of forced labour or child labour were identified during the reporting period.
Policy and Procedure Reviews: The Company regularly reviews and updates its policies and procedures to ensure they remain aligned with evolving legal requirements, industry standards and emerging best practices.

These measures support the Company’s ongoing eﬀorts to strengthen its approach to identifying and managing modern slavery risks within its operations and supply chains.

MEASURES TAKEN TO REDMEDIATE MODERN SLAVERY OR LOSS OF INCOME FROM MOST VULNERABLE

While no instances of modern slavery or associated loss of income to vulnerable families were identified during the reporting period, the Company maintains remediation and escalation processes to address potential concerns within its operations or supply chains. Under the Procurement Policy and Child Remediation Policy, suspected cases are investigated and appropriate corrective action is taken, with a focus on the welfare of aﬀected individuals and remediation of identified issues.

CONSULTATION

This statement has been prepared in consultation with relevant stakeholders, including central Group functions that support the entities listed in the Appendix. These consultations involved discussions and gathering information on modern slavery risks, relevant policies and procedures, and contributions to the content of this statement.

CONFIRMATION

This statement constitutes the Modern Slavery Statement for the financial year ending 2025 in accordance with

UK Modern Slavery Act 2015
Australia’s Modern Slavery Act 2018 (Cth)
California Transparency in Supply Chain Act 2010

This statement has been approved by the Executive Board of William Grant & Sons Limited.

Graeme Jenkins

Chief Financial Oﬀicer

21 August 2026

Appendix 1: List of Reporting Entities

1. William Grant & Sons Brands Ltd
2. William Grant & Sons Distillers Ltd
3. William Grant & Sons Commercial Ltd
4. William Grant & Sons International Ltd
5. William Grant & Sons UK Ltd
6. William Grant & Sons Irish Brands Ltd
7. Quality Spirits International Ltd
8. William Grant & Sons Australia Pty Ltd
9. William Grant & Sons USA Corp
10. William Grant & Sons Inc
11. William Grant & Sons Americas LLC
12. William Grant & Sons US Distillers LLC
13. Tuthilltown Spirits LLC
14. William Grant & Sons Canadian Whiskey Ltd
15. The Famous Grouse Limited
16. Matthew Gloag & Son Limited

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