Modern Slavery Statement 2022

This statement reports on the approach of Ascona Group Holdings Ltd and its subsidiaries (together, Ascona Group) to assessing and comprehending potential risks of modern slavery within our business and the steps taken to ensure our business and supply chains are free of slavery and human trafficking.

This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 March 2022.

Ascona Group is committing to preventing human trafficking and slavery in every area of the business and supply chain. We recognise our responsibility to take a proactive approach on this at all times.

Our Business, Structure and Supply Chains

We own and operate roadside retail destinations throughout the United Kingdom, offering fuel, convenience retail, valeting and ‘Food to Go’, together with ancillary services. Our locations in Wales and England are considered to be relatively low risk in relation to human trafficking and slavery.

Our sector is one in which non-EEA nationals typically make up a high proportion of the working population so there is a greater potential for possible modern slavery or human trafficking activities. However, we strive to ensure our suppliers are not involved in and take reasonable steps to prevent slavery and human trafficking activities and that all of our employees and workers are paid in compliance with all applicable employment legislation.

We have identified that there may be risk further down the fuel supply chain as some products initiate outside the EEA where typically there may not be as much focus on prevention of slavery and trafficking. However, going forward when entering into new contracts or renewing existing contracts, we are committed to requesting our suppliers to warrant that they and in turn their suppliers are not involved in and take reasonable steps to prevent slavery and human trafficking activities.

Due Diligence, Risk Assessment and Management

The management team reviews the risk associated with our commercial activities on an ongoing basis, including in relation to the potential for modern slavery to occur. We believe that, as no occurrences of modern slavery have been identified within the activities in which we are involved, we – and our supply chain – are low risk.

Ascona Group carries out ‘right to work’ checks on all prospective employees during our recruitment process. Any reports of failure to comply with employment legislation is immediately investigated and rectified and/or referred to disciplinary proceedings as necessary. If we encountered any reason to believe there may be an instance of slavery or human trafficking, this would immediately be investigated and escalated to the executive team and authorities, and we will always co-operate fully with any investigations by the authorities.

Policies, Training & Awareness

We operate and regularly update our policies in order to carry out business ethically, legally and with integrity. These include our Anti-Slavery and Human Trafficking Policy, our Whistleblowing Policy, Equal Opportunities Policy and Anti-harassment and Bullying Policy. All such policies are clear that employees can - and are encouraged - to identify and raise concerns, and serve to raise awareness throughout the business of the key risks to the company, employee personal responsibilities and how to report any concerns.

We regularly update our Area and Site Managers on the fundamental importance of our ‘right to work’ checks and other employment law obligations in relation to our staff.

Performance Indicators

Ascona Group has not received any reports, feedback or concerns in relation to slavery or human trafficking within our business from any source - including law enforcement agencies, local authorities, suppliers, employees, customers or the general public - which we are satisfied provides a reasonable litmus test in relation to our practices, procedures and supply chains.

We will continue to diligently review all available indicators in order to ensure our business and supply chains remain free of slavery and human trafficking.

Approval

This statement is approved by the Board of Directors of Ascona Group Holdings Ltd.