1. Introduction

• Millennium Cash and Carry Ltd (“MCC”) is a wholesale company trading in Fast Moving Consumer Goods (“FMCG”), primarily food, beverages and related consumable items. MCC and its subsidiaries are based wholly within the UK and primarily purchase from major UK based brandowners with a mix of UK and overseas produced items.

• MCC also buys from small to medium producers located in the UK and around the world. In relation to smaller producers, MCC will buy from distribution and consolidation agents.  This tends to be the way in which particular markets are set up such as wineries who sell their goods to negociants which have the contacts and size to distribute those wines around domestic or international markets.

• MCC is an importer and will buy some goods from overseas markets. MCC assists a number of brands to achieve a route to market in the UK.  MCC aims to build up long term and collaborative relationships with trusted suppliers with which it works to reduce a variety of risks. 

2. Policy statement

• This statement is made under the Modern Slavery Act 2015 and is our second policy statement. This is made in relation to the financial year ended 31 May 2024. 

• Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

• We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

• This policy also applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

• This policy does not form part of any employee's contract of employment and we may amend it at any time.

3. Risk assessments

• MCC operates a proportionate and risk based approach to the level of due diligence and vetting procedures for our supply chains in addressing all risks that MCC may be exposed to. Should any concerns arise in relation to modern slavery, MCC will work closely with any relevant supplier to address those whether or not they were previously considered low risk.

• The products supplied by MCC are predominantly made by large global brands to very high standards. These products are also generally subject to either high levels of automation (such as in bottling and packaging) or otherwise low levels of manpower to product produced (such as where food or drink are made in very large batches which can require lengthy time or processes to complete). 

• MCC recognizes that the greatest risk in relation to human slavery arises within the agricultural elements of production. This is where the core ingredients for the food and beverages are grown and picked or harvested.  This can include seasonal work that is heavily reliant on manpower, although more in relation to fruits than grains, vegetables or animal produce.

• MCC considers it reasonable to rely on the practices and procedures of the larger brandowner suppliers that it purchases from. These products are generally household names, and together with the low requirement for human action in the supply chains, the exposure to modern slavery in relation to those products is considered low.  Where MCC does not purchase directly, but the products in question are still produced by such household name brandowners, MCC considers it remains reasonable to rely on the practices and procedures of those larger brandowner producers.  MCC considers that any issues surrounding slavery in these supply chains are likely to be mainstream news before MCC itself would have any realistic chance of discovering for itself.  MCC’s influence and access to information is limited in such supply chains.  This reliance does not require positive steps and none have been taken in the year ended 31 May 2024.

• MCC recognizes that in relation to smaller producers it ought to take steps to seek assurances as to their practices and procedures to limit or eliminate slavery in their production supply chains. To the year ended 31 May 2024 MCC has not yet taken steps to pursue this, but intends to introduce this practice in future years. As such, there are currently no performance indicators to be assessed for this.

• No reports have been made to MCC in the year to 31 May 2024 of any instances of actual or suspected modern slavery or human rights abuses relating to any forced labour of any kind in its supply chains.

    4. Responsibility for the policy

• The Board of Directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

• The Due Diligence compliance officer has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

• Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

• You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the compliance manager.

    5. Compliance with the policy – employees etc

• You must ensure that you read, understand and where applicable comply with this

• The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

• You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

• You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

• If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager as soon as possible.

• If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your

• We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the Employee Handbook.

     6. Communication and awareness of this policy

• Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as

• Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

    7.  Breaches of this policy

• Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

• All potential breaches of modern anti-slavery measures will be investigated when identified. We may suspend or terminate our relationship with other individuals and organisations working on our behalf or supplying us if they breach this policy on a case by case basis. MCC considers the best outcome is to work with partners to improve anti-slavery measures where possible.

This statement has been signed and approved by Shyam Lakhani, Director, Millennium Cash & Carry Ltd on 13^th March 2025.