Corporate Governance Code

(The information contained in this document was last reviewed on 26 October 2026) In this document, unless the context otherwise requires: > reference to James Cropper or to the Company is to James Cropper Plc (and reference to our, us and we is to be construed accordingly); and >reference to the Group is to the group of companies of which James Cropper is the parent

Introduction

The Company's shares are listed on AIM and are subject to the AIM Rules of the London Stock Exchange. Under AIM rule 26, the Company adopted the QCA Corporate Governance Code (2023 edition) (the QCA Code). The choice of code to adopt was important to us. We wanted to be sure that we would proactively embrace whatever code we opted for and not end up with a code that could stifle us and result, on a comply or explain basis, with us describing why certain requirements were not appropriate. We believe that the QCA Code provides us with the right governance framework: a flexible but rigorous outcome-oriented environment in which we can continue to develop our governance model to support our business.

Corporate governance principles applicable to James Cropper

Corporate governance principles

As a result of deciding to apply the QCA Code, the corporate governance principles which now apply to us are those contained in the QCA Code. These are:

  1. Establish a purpose, strategy and business model which promote long-term value creation
  2. Promote a corporate culture that is based on ethical values and behaviours
  3. Seek to understand and meet shareholder needs and expectations
  4. Take into account wider stakeholder interests, including social and environmental responsibilities, and their implications for long-term success
  5. Embed effective risk management, internal controls and assurance activities throughout the organisation
  6. Establish and maintain the Board as a well-functioning, balanced team led by the Chair
  7. Maintain appropriate governance structures and ensure directors have the necessary experience, skills and capabilities
  8. Evaluate board performance based on clear objectives, seeking continuous improvement
  9. Establish a remuneration policy supportive of long-term value creation, purpose, strategy and culture
  10. Communicate how the Company is governed and is performing by maintaining a dialogue with shareholders and other key stakeholders

Chair's Introduction

"The Board is committed to high standards of corporate governance, with robust oversight, clear accountabilities and effective risk management supporting long-term value creation." Mark Cropper Non-Executive Chair

Chairman’s corporate governance statement

Mark Cropper

Dear Shareholder,

On behalf of the Board, I am pleased to present our Corporate Governance Report for the period ended 28 March 2026. This statement provides an overview of our governance framework and how the Board discharges its responsibilities.

The Board recognises the fundamental importance of effective governance to long-term value creation and is committed to continuous improvement.

We report against the QCA Corporate Governance Code. FY26 is our first year of reporting against the 2023 version of the Code, and I am pleased to report that we complied with its principles in full.

In addition to the QCA Code, the Board monitors the FRC’s Corporate Governance Code, and developing best practice, to ensure our approach remains robust.

FY26 has been an important year for the Group, with a clear strategy established under the leadership of David Stirling and a decisive move into execution across the business. There were no new appointments to the Board during FY26, which has provided continuity as the executive team have transitioned to delivery of the strategic plan. As was announced in July 2025, Sarah Miles stepped down from the Board at the conclusion of the Company’s AGM in September 2025.

Subject to the election and re-election of Directors by shareholders, following the AGM in September 2026, the Board will comprise myself (as Non-Executive Chair) together with two Executive Directors (CEO and CFO) and three independent Non-Executive Directors, which presents a strong balance of experience, skills and knowledge, together with robust independent challenge.

In late 2025, the Board carried out an internal evaluation, led by Senior Independent Director Martin Court, as part of its commitment to continuous improvement. The findings and agreed actions resulting from that review are summarised on pages 76 and 77 of the 2026 Annual Report.

The Board remains committed to open and constructive dialogue with shareholders. Throughout the year, members of the Board engaged with shareholders to discuss business performance, the Group’s strategic direction and developments during the year, and to provide opportunities for questions
and feedback.

Following the Board’s approval of the Group’s new strategy, a Capital Markets Event was held in London in June 2025 for institutional investors and analysts. This was followed by an Investor Day for prospective shareholders at the Group’s principal site in Burneside. Together, these events provided opportunities to engage with members of the Board and Executive team, discuss strategy and performance, and gain first‑hand insight into the Group’s operations and facilities.

Feedback from shareholders is always welcomed and provides valuable insight into the views of our investors. As a Board, we are keen to understand the interests of our investors, and I am very grateful to those who took the time to engage with us this year.

Mark Cropper

Non-Executive Chair

Governance Structures

QCA CODE AND STATEMENT OF COMPLIANCE

The Company’s shares are listed on the Alternative Investment Market (AIM) of the London Stock Exchange and subject to AIM rules. We continue to adopt the QCA Corporate Governance Code (the ‘Code’) which provides an appropriate and practical governance framework and is implemented through robust practices and systems of control aligned to our business model. We consider that meaningful compliance with the principles of the Code should provide shareholders with confidence in how the Group operates. We are a member of the QCA and, during the year, complied with all principles of the 2023 version of the code in full.

THE BOARD

The Board is responsible for promoting the long-term sustainable success of the Group for the benefit of its shareholders and supporting all stakeholders. The Board establishes the Group’s purpose and sets its strategic direction, ensuring that these remain aligned with the Group’s culture and values.

The Board consists of Senior Executive Management together with experienced Non-Executive Directors (details of Board members can be found on pages 71-72 of our 2026 Annual Report and Accounts.). The Board meets regularly in accordance with its planned calendar and otherwise as may be required. Meetings take place in person or where necessary by video conferencing. All Directors have full and timely access to relevant information. The Board maintains a schedule of matters reserved for its approval, which is regularly reviewed and made available on the Group’s website.

BOARD COMMITTEES

The Board delegates certain matters to its Audit & Risk, Remuneration and Nomination Committees which are comprised of Non-Executive Directors. Written terms of reference govern the responsibilities of the Committees, which are reviewed regularly by the Board and made available on the Group’s website.

The Committees ensure that there is independent oversight of the matters within their remit and assist the Board in fulfilling its responsibilities. Where appropriate, each Committee has the power to appoint external advisors to support the performance of its duties. Full reports from each of the Committees, detailing their responsibilities, key considerations and actions during the year, are set out from pages 79, 81 and 83 in the 2026 Annual Report.

EXECUTIVE COMMITTEE

The Executive Committee is responsible for developing strategy recommendations to the Board, executing the Board’s approved strategy, day-to-day management of the Group’s operations, and developing and implementing the Group’s safety, environmental, social and governance framework.

The Executive Committee comprises the Executive Directors, business unit Managing Directors and the General Counsel and Company Secretary. The Committee operates in accordance with written terms of reference, which are reviewed regularly and are available on the Group’s website.

The Executive Committee meets monthly to review progress against the Group’s strategic plan, business performance and key operational developments. Oversight of principal risks and emerging issues is embedded within the Committee’s responsibilities and is informed by information collected through the Group’s risk management framework. On a quarterly basis, the Executive Committee undertakes a structured review of principal risks and emerging issues, ensuring that risk considerations are integrated with performance monitoring, strategic execution and resource allocation.

Where appropriate, matters are escalated to the Board for consideration. This approach supports a disciplined, execution‑focused governance framework and reinforces the effective management of risk in support of long‑term value creation. Feedback from Executive Committee meetings is shared with the Board.

DIVISIONAL SENIOR LEADERSHIP TEAMS

The Senior Leadership Teams within each of our Advanced Materials and Paper & Packaging businesses have day-to-day responsibility for managing operations, monitoring performance and commercial developments, the identification and management of risks, and delivering business strategy.

The Senior Leadership Teams comprise Divisional Managing Directors together with divisional senior management, supported by members of Group functional teams for Finance and HR.

Meetings take place monthly, with feedback being shared with the Executive Committee.

OTHER GOVERNANCE STRUCTURES

Other key governance structures within the Group include:

Pensions Steering Committee

The Pensions Steering Committee is responsible for supporting the Board in the discharge of the Company’s obligations and powers in connection with the Company’s defined benefit pension schemes. It closely monitors performance of the schemes with the Trustee and investment managers, engages with the Trustee in connection with investment strategy, and ensures that appropriate governance arrangements exist.

The Committee is chaired by the CFO and comprises other Board members and senior management. It meets quarterly and as required from time to time.

ESG Working Group

In 2024, we launched our ESG Working Group, which meets quarterly to support the development and delivery of ESG objectives. The Working Group is chaired by the General Counsel and Company Secretary, and comprises a diverse range of knowledgeable and passionate people from across the Group at all levels and from a range of sites who actively participate. For more information on the ESG Working Group, see our ESG report on pages 48–56 of our 2025 Annual Report and Accounts.

DIVISION OF RESPONSIBILITIES

The roles of the Chair and CEO are separate, clearly understood and agreed by the Board.

Non-Executive Chair

The Chair leads the Board, ensuring its effectiveness while taking account of the interests of the Group’s various stakeholders, promoting high standards of corporate governance. Key responsibilities include:

  • Chairing the Board, its Nomination Committee and General Meetings.
  • Ensuring the Directors effectively contribute and engage in constructive debate.
  • Setting the Board’s agenda in conjunction with the CEO and Company Secretary.
  • Ensuring that the Board’s effectiveness is reviewed annually and leading the performance evaluation of the CEO and Non-Executive Directors.
  • Ensuring that effective induction and training programmes exist and encouraging the continued development of Directors and the Board as a whole.
  • Serving as an ambassador for the Group and its products and services, culture and values.
  • Engaging with shareholders and other stakeholders, and ensuring that the Board develops an understanding of external views and interests.

Chief Executive Officer

The CEO is responsible for developing the Group’s strategy and the operating performance of the Group. Key responsibilities include:

  • The effective management of the Company’s businesses.
  • Leading development of the Company’s strategic direction and implementing the agreed strategy.
  • Developing objectives for the Executive team.
  • Managing the Company’s risk profile and maintaining an effective framework of controls.
  • Ensuring effective succession plans are in place and leading in the development of people.
  • Ensuring effective communication with shareholders and key stakeholders on business strategy and performance.
  • Providing regular operational updates to the Board.

Senior Independent Director

The responsibilities of the Senior Independent Director include:

  • Providing a sounding board for the Chair and acting as an intermediary for Non-Executive Directors where necessary.
  • Working closely with the Chair and other Directors, and/or shareholders to resolve issues as may be required from time to time.
  • Leading the appraisal of the performance of the Chair.

Non-Executive Directors

The Non-Executive Directors bring insight and experience to the Board. They have responsibility for:

  • Constructively challenging the strategies proposed by the Executive Directors.
  • Scrutinising the performance of management in achieving agreed goals and objectives.
  • Devoting time to developing and refreshing knowledge and skills, and being well-informed about the Company.
  • Playing a leading role in the functioning of the Board Committees.
  • Meeting with the Senior Independent Director to review the Chair’s performance and other matters.

The Board is supported by the Company Secretary, who assists in upholding corporate governance standards. The Company Secretary ensures compliance with Board procedures and provides support to the Chair. He advises the Board on corporate governance developments and ensures that the Board receives information in a timely manner.

BOARD ACTIVITIES

The Board held 7 scheduled Board meetings during FY26, which were scheduled to coincide with key dates in the Group’s financial calendar. In addition to regular scheduled meetings, a number of additional meetings took place during the year in order to deal with specific business arising from time to time. Principal considerations at Board meetings include:

  • Health, safety and environment
  • Strategy
  • Financial performance
  • Risk
  • People and culture
  • Stakeholder engagement
  • Governance

In advance of all Board meetings the Directors are supplied with papers covering the matters to be addressed. Members of the Executive Committee, senior management, or third parties may also attend meetings, or parts of meetings, by invitation from time to time. Executive Directors may attend Committee meetings (or parts of such meetings) by invitation where required. The Company Secretary is responsible to the Board for the timeliness and quality of information.

BOARD COMPOSITION

The Board currently comprises two Executive Directors, a Non-Executive Chair and three independent Non-Executive Directors.

Biographies for all Board members are set out on pages 71-72 of the 2026 Annual Report and Accounts.

Further information on Board composition and succession planning can be found in the Nomination Committee report, which can be found on pages 81-82 of the 2026 Annual Report.

BOARD SKILLS AND EXPERIENCES

The Board recognises the importance of Directors bringing a strong balance of skills, knowledge, and experience to delivery of the Company’s strategic objectives. During the year, the Nomination Committee reviewed its assessment of the knowledge, skills, experience, and diversity on the Board. Updated outcomes from this exercise were reviewed by the Board and used to inform succession planning. This process is the subject of regular review to best ensure the Board remains well balanced.

DIRECTOR INDEPENDENCE

The Board reviews the independence of its Non-Executive Directors regularly. Taking into account all circumstances, the Board considers Non-Executive Directors Martin Court, Lyndsey Scott and Jon Yeung to be independent. Mark Cropper, David Stirling and Andrew Goody are not considered by the Board to be independent.

The Board considers that its composition represents a good balance of operational, commercial, technical and financial knowledge, entrepreneurial leadership and robust independent challenge.

CONFLICTS OF INTEREST

The Companies Act 2006 and the Company’s Articles of Association require the Board to consider actual or potential conflicts of interest. The Board has policies for managing and, where appropriate, authorising actual or potential conflicts of interest and related party transactions. Directors are required to declare any interests they or their close family members have in third-party organisations, as well as other circumstances which could give rise to a conflict of interest. Registers of related parties and third-party interests are regularly reviewed by the Board. Directors are required to seek clearance from the Chair before taking on any new appointments to ensure that any potential conflicts of interest can be identified and addressed appropriately.

At the outset of every Board and Committee meeting, Directors are required to declare any actual or potential conflicts in relation to matters on the agenda. Where a Director has any actual or potential conflict of interest in relation to a matter under consideration, that Director is not involved in the relevant discussion or  decision‑making.

BOARD EFFECTIVENESS

The Board adopts an inclusive and open style which encourages collaboration and the free flow of information between Executive and Non-Executive Directors. Board  members are encouraged to discuss matters openly and add value by sharing personal skills and experiences. No individual or group of individuals dominates the Board’s decision-making process. All Directors communicate regularly, and appropriate contact with senior executives within the Group is encouraged. Separate meetings of the Non-Executive Directors are held during the year to discuss strategy and performance and to enhance independent oversight and stakeholder accountability.

During the year, the Board undertook an internal effectiveness review led by the Senior Independent Director (SID). The review comprised a series of one‑to‑one discussions between the SID and each Board member, framed around key themes including strategy, the quality and organisation of Board papers, and Board dynamics and culture. The effectiveness of the Board’s Committees was also considered. The insights gathered from Directors, together with the outcomes of these discussions, were reviewed by the SID, the Company Secretary and the Chair and developed into a series of recommendations, which were presented to and considered by the Board.

The review concluded that the Board is operating effectively and benefits from a strong culture of openness, collaboration and constructive challenge. During the year, the Board’s engagement supported improved strategic focus and alignment, together with more effective oversight of the delivery of the Group’s objectives. Board dynamics were viewed positively, with constructive interaction between Executive and Non‑Executive Directors, effective leadership, and well‑established Committee structures supporting the Board’s work. The review also noted the positive impact of Non‑Executive Directors undertaking site safety walks, which has increased Board exposure to operational activities and strengthened engagement with colleagues across the business.

The review also identified areas where the Board could further strengthen its effectiveness, including continuing to enhance oversight of strategic delivery, maintaining an appropriate balance between strategic and operational matters in Board discussions as the executive team progresses the business plan, and continuing to refine the quality and consistency of management information. The importance of maintaining strong Board dynamics and culture, supported by effective meeting planning and a disciplined approach to agenda setting, was reaffirmed. In addition, it was agreed that the Nomination Committee would deepen its oversight of succession planning for senior management to ensure a strong and sustainable leadership pipeline.

Recommendations from the previous  effectiveness review undertaken in FY25 included a review of strategic planning and delivery, reducing the volume of Board papers to enhance focus, expanding the remit of the Audit Committee to strengthen oversight of risk, and further developing Board and Committee meeting planning. Each of these recommendations was implemented during the year.

The Board recognises the importance of regular effectiveness reviews as part of its commitment to continuous improvement in how it operates and discharges its responsibilities.

DIVERSITY

The Board recognises the benefits of diversity at all levels of the organisation. Diversity on the Board was reviewed in the year by the Nomination Committee and this approach will help support effective future succession planning. Our female representation on the Board is 17%. For more information on the Group’s approach to diversity, see the Nomination Committee Report from pages 81-82 of the 2026 Annual Report and Accounts.

INDUCTION AND PROFESSIONAL DEVELOPMENT

Upon joining the Group, Directors are provided with an induction which ensures that they are fully informed and have the necessary support to perform their roles effectively. This typically involves meetings with members of the Board together with senior management, visits to operational sites and the provision of information on the Group’s products, markets and strategy, and key governance arrangements.

The Chair ensures that Directors receive information to enable them to perform their duties properly. Briefings are provided to the Board on governance, regulatory, financial and legal matters by the Company Secretary, CEO and CFO and external advisors where required. Directors are aware of their responsibility to regularly update their skills and knowledge.

SUPPORT

Directors can obtain independent professional advice at the Group’s expense in performance of their duties. None of the Directors obtained independent professional advice in the period under review. All Directors have access to the advice and the services of the Company Secretary and access to senior management across the Group where required.

ELECTION AND RE-ELECTION OF DIRECTORS

In accordance with best practice, all Directors continuing in office will stand for election (or re-election) annually at the Company’s AGM.

RISK MANAGEMENT AND INTERNAL CONTROLS

The Board recognises that the delivery of the Board’s strategy requires the adoption of an appropriate level of risk. Effective risk management is therefore fundamental to achieving the Group’s strategic objectives.

The Group’s strategic risk management framework adopts a tiered approach, with leaders across the organisation being responsible for the management of risks in conjunction with their strategic objectives. The framework is supported by guidance and tools designed to promote the consistent identification and management of risks across the Group, enabling consolidated review and oversight of principal and emerging risks by the Executive Committee, the Audit & Risk Committee and the Board.

The Board, supported by the Audit & Risk Committee, regularly reviews the effectiveness of the Group’s risk management and internal control systems. These systems are designed to manage, rather than eliminate, risks and to provide reasonable assurance that the Group’s strategic objectives can be achieved.

RELATIONS WITH SHAREHOLDERS

The Board recognises the importance and benefits of regular engagement with shareholders and the Group’s other stakeholders. Further information is contained in the s.172 Statement on pages 50-53 of our 2026 Annual Report and Accounts.

ANNUAL GENERAL MEETING (AGM)

Our AGM will be taking place on 9 September 2026. Following the meeting to consider the proposed resolutions, there will be an opportunity for shareholders to meet the Directors informally.

QCA Code

Set out in the following table is a list of the disclosures required to be published by us under the QCA Code. The table also indicates where each disclosure appears in our Annual Report or in this document. As explained on page 1 of this document, the disclosures appear in the locations recommended in the QCA Code. Unless stated otherwise, reference to a page is to a page in this document.
PRINCIPLE
HOW WE APPLY THE CODE
-
-
Establish a purpose, strategy and business model which promote long‑term value creation
The Group’s purpose, strategy and business model can be found in the Strategic Report, particularly on pages 10-29 of the 2026 Annual Report. Information on the Board’s role in establishing and overseeing strategy is included in the Corporate Governance Report on pages 73-77.
Promote a corporate culture that is based on ethical values and behaviours
Information regarding the Company’s purpose and business model can be found in the Strategic Report on pages 18-29 of the 2026 Annual Report. Information regarding the Company’s approach to culture (including people, safety, diversity, ethics and sustainability) can be found in the ESG Report on pages 54-65.
Seek to understand and meet shareholder needs and expectations
Information regarding the Board’s arrangements for engaging with stakeholders and considering stakeholder interests, including engagement during the year in question, can be found in the s.172 Statement on pages 50-53 on the 2026 Annual Report.
Take into account wider stakeholder interests, including social and environmental responsibilities, and their implications for long‑term success
Information regarding the Board’s arrangements for engaging with stakeholders and considering stakeholder interests, including engagement during the year in question, can be found in the s.172 Statement on pages 50-53 of the 2026 Annual Report. Environmental and social matters are addressed in the ESG Report on pages 54-65.
Embed effective risk management, internal controls and assurance activities throughout the organisation
Information regarding how the Board has embedded effective risk management (including arrangements for identifying, reviewing and managing current and emerging risks) and gains assurance that risk management arrangements are effective can be found in the Risk Management Report on pages 44-49 of the 2026 Annual Report. Information concerning oversight of the Group’s internal controls can be found in the Audit & Risk Committee’s Report on pages 79-80. Information concerning governance in relation to climate-related risks and opportunities can be found in the Non-Financial and Sustainability Information Statement on pages 66-70. Information concerning the monitoring and determination of external auditor independence can be found in the Audit & Risk Committee Report on pages 79-80.
Establish and maintain the Board as a well-functioning, balanced team led by the Chair.
Information regarding the operation of the Board and its Sub-Committees, and the division of responsibilities between Board members, can be found in the Corporate Governance Report on pages 73-77 of the 2026 Annual Report. Information regarding Board activities in the year, principal considerations at Board meetings and Board meeting attendance, can be found in the Corporate Governance Report on pages 73-77. Information regarding the independence of Board members can be found in the Corporate Governance Report on page 76. Information regarding the support of the Company Secretary to the Board can be found in the Corporate Governance Report on page 75.
Maintain appropriate governance structures and ensure directors have the necessary experience, skills and capabilities
Information regarding the skills and experiences of each individual Director can be found on pages 71-72 of the 2026 Annual Report. Information regarding the skills and capability assessment carried out by the Board in the year can be found in the Corporate Governance Report on page 76-77. Information about Board succession processes can be found in the Nomination Committee Report on pages 81-82. Information regarding Non-Executive Director inductions and continuous professional development can be found in the Corporate Governance Report on page 77.
Evaluate Board performance based on clear objectives, seeking continuous improvement.
Information regarding the effectiveness review carried out by the Board in the year, including the review process together with identified recommendations, and progress made in the year against previous recommendations, can be found in the Corporate Governance Report on pages 76-77 of the 2026 Annual Report.
Establish a remuneration policy supportive of long‑term value creation, purpose, strategy and culture
The Directors’ remuneration policy and practices are described in the Remuneration Committee Report on pages 83-90 of the 2026 Annual Report, including how remuneration supports long‑term value creation and strategic execution.
Communicate how the Company is governed and is performing by maintaining a dialogue with shareholders and other key stakeholders.
Information regarding the Board’s arrangements for engaging with shareholders and other stakeholders, including engagement during the year in question, can be found in the s.172 Statement on pages 50-53 of the 2026 Annual Report.