Modern Slavery and Human Trafficking Statement

Background

James Cropper plc (the “Company”), together with its subsidiary businesses (collectively the “Group”), is a market leader in the development and manufacture of advanced materials and paper products. The Group is committed to preventing modern slavery, human trafficking, forced labour and all forms of exploitation within its operations and supply chains. This includes adopting a zero-tolerance approach to modern slavery, which is a standard expected of all employees, contractors, suppliers and business partners. The Group will not support or deal with any business known or suspected to be involved in slavery or human trafficking. This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps taken during the relevant financial year by the Group to prevent modern slavery and human trafficking in its business and supply chains.

OUR BUSINESS AND SUPPLY CHAINS

Headquartered from its Burneside site in the UK, the Group operates manufacturing operations in the UK and USA and undertakes commercial activities globally. The Group is divided into two principal businesses:

  • The Advanced Materials business operates at the forefront of materials science, developing state-of-the-art nonwoven materials and electrochemical coatings, which are supplied to leading innovative equipment manufacturers globally from four locations in Burneside (UK), Crewe (UK), Launceston (UK) and Schenectady (USA).
  • The Paper & Packaging business develops and manufactures bespoke creative papers and luxury packaging incorporating industry-leading thermoformed fibre solutions, innovative recycled fibre capabilities and colour expertise, which are supplied to some of the world’s most well-known and prestigious global brands, creative paper merchants, printers and publishers from its base in Burneside (UK).

Supply chains across each business incorporate raw materials, manufacturing inputs, logistics, professional services and other business-critical services. We recognise that modern slavery risks can arise at different tiers of the supply chain and that risk levels vary by geography, sector and labour practices.

OUR POLICIES AND STANDARDS

The Group’s approach is underpinned by its Modern Slavery and Human Trafficking Policy, which was most recently updated in February 2026. The policy:

  • Condemns all forms of modern slavery, forced or compulsory labour and human trafficking.
  • Requires compliance with applicable laws and internationally recognised standards.
  • Reinforces commitments to act ethically and with integrity in business relationships.
  • Sets clear expectations for ethical conduct, fair treatment, freedom of association and safe working conditions.
  • Provides for reporting (including anonymously through an independent whistleblowing service) and remediation where concerns are identified.

Breaches of the Policy are regarded as misconduct, and the Group has a strict policy of non-retaliation against employees reporting suspected breaches. The Policy is published internally for employees to view.

DUE DILIGENCE AND SUPPLIER ADHERENCE

The Group’s approach for identifying modern slavery forms part of its strategic risk management framework which is integrated throughout the Group. Key elements include:

  • Identification and assessment of modern slavery risks within operations and supply chains, consistent with Home Office guidance.
  • Supplier due diligence proportionate to risk, including the use of supplier codes of conduct and ethical sourcing expectations and evidence-backed assessment.
  • Periodic reviews and gap analysis against statutory requirements and best practice.

GOVERNANCE AND OVERSIGHT

Oversight of modern slavery and human trafficking risk management is embedded within the Group’s established governance framework. Day‑to‑day monitoring is carried out by relevant personnel, with management teams providing ongoing oversight and challenge to ensure that risks are identified, assessed and appropriately mitigated. Building on this, the Executive Committee reviews broader risk matters on a quarterly basis and, supported by the Compliance Steering Committee, undertakes an annual review of the Group’s modern slavery governance and arrangements, ensuring these remain effective and suitably aligned to requirements and best practice. Ultimate responsibility rests with the Board, with specific focus on risk management and whistleblowing falling within the remit of the Audit & Risk Committee, which provides scrutiny and assurance on the adequacy and effectiveness of systems of control.

TRAINING AND AWARENESS

The Group is committed to building awareness and capability across its businesses. Training is provided to employees on policies and standards, with enhanced and targeted training for individuals in supplier-facing or higher risk roles, such as procurement, human resources, supply chain and sales. This supports early identification of risks and appropriate escalation.

REPORTING AND REMEDIATION

Employees, workers and third parties are encouraged to raise concerns without fear of retaliation. Concerns can be reported through established internal reporting and whistleblowing channels (including through an independent reporting service provided by SafeCall where reports can be made entirely anonymously). Where issues are identified, the Group is committed to taking appropriate and proportionate action, including remediation and continuous improvement of controls.

CONTINUOUS IMPROVEMENT

The Group recognises that addressing modern slavery risks is an ongoing process, and will continue to review and enhance arrangements, informed by legislation, Home Office guidance and evolving best practice. This statement will be reviewed annually and updated as appropriate.

APPROVAL

This statement has been reviewed and approved by the Board of Directors. It is signed on behalf of the Board and published on the Group’s website in accordance with the Modern Slavery Act 2015.

 

David Stirling

Chief Executive Officer

On behalf of the Board of James Cropper plc

13 April 2026