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Menzies Distribution Solutions – National High Cube Network & Smarter Supply Chain Solutions

Modern Slavery Policy

PURPOSE
This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and is published by Menzies Distribution Services Limited on behalf of Menzies Distribution Services Limited (and its subsidiary companies, including its wholly owned subsidiary Menzies Distribution Solutions Limited) (together the “Menzies Distribution Group Companies”) each carrying on business in the UK and having an annual turnover of approximately £225 million. References in this Statement to “we”, “us” or “our” are to all of the Menzies Distribution Group Companies. 

This is our updated statement for the financial year ending 31 December 2025 and it details the steps taken by us to ensure that slavery and human trafficking do not occur in our supply chains or any part of our business.


OUR BUSINESS
The Menzies Distribution Services Ltd businesses operate as one of the UK’s largest logistics services, offering transport, warehouse and value-added services to customers in multiple sectors across the UK as well as international freight forwarding services.

The Menzies Distribution Services Ltd companies comply with applicable legislation relating to employee terms and conditions, and all employees are paid at least the applicable National Minimum Wage or National Living Wage.

SUPPLY CHAINS RISK ASSESSMENT
We recognise that modern slavery is a crime and a fundamental violation of human rights. We are committed to ensuring there is transparency in our business and in our approach to tackling modern slavery throughout our supply chains.

We work with a large number of third parties, including contractors, suppliers and business partners (our “Suppliers”), many of whom are critical to our success. While the nature of our operations and our predominantly UK-based supply chain means the risk of modern slavery within our business is considered limited, we remain vigilant and proactive in ensuring ethical practices are upheld.

Our supplier due diligence programme adopts a risk-based approach and may include assessment of:

• geographic risk;
• sector specific risk;
• use of temporary or agency labour;
• labour-intensive operations;
• modern slavery policies and disclosures;
• adverse media screening;
• contractual compliance commitments; and
• supplier responses to sustainability and ethical trading questionnaires.

Enhanced due diligence may be undertaken where elevated modern slavery risks are identified.

We seek to ensure that we engage only with those Suppliers who uphold the values to which we adhere and require that all our Suppliers, through contractual commitments, act ethically and with integrity at all times, sharing our commitment to humane and safe working practices.

Whilst we are not aware of any incidents of modern slavery within our supply chains or any part of our business to- date, we continue to undertake risk assessments and analysis across our organisation to ensure consistency, comprehensiveness and quality in the manner and mode of Supplier assessment, both pre and post-engagement. Where our Suppliers operate in sensitive industries and countries, we undertake enhanced risk assessments and monitoring measures to ensure that slavery and human trafficking does not occur in our supply chains. 3 Modern Slavery and Human Trafficking Statement 2025 We recognise our responsibility to respect internationally recognised human rights and expect our employees, suppliers and business partners to uphold equivalent standards throughout their operations and supply chains.

POLICIES, PROCEDURES AND COMPLIANCE
We take our responsibilities seriously and aim to demonstrate our commitment to operating fairly, honestly and in compliance with all applicable legislative, regulatory and ethical requirements and believe we must foster a culture in which integrity, responsibility and ethical values are at the very core of all our activities and decision-
making processes and any abuse of human rights, either within our business or by anyone employed by or associated with it, will not be tolerated. 

Responsibility for oversight of the Menzies Distribution Group's approach to modern slavery rests with the Board of Directors. Day-to-day responsibility for implementation, monitoring and reporting sits with the General Counsel, supported the Human Resources and Operational Management teams and those responsible for procurement. Regular updates regarding modern slavery risks, controls and compliance activities are provided to the Board. 

A key focus of our Compliance Programme is to review, refresh and improve certain of our compliance policies, procedures, training and controls, and to seek improved engagement with our people and our suppliers. We are committed to ensuring that our business operates ethically at every level and that our people and suppliers understand and share this commitment.

Our Group Anti-Slavery and Human Trafficking Policy and Anti-Bribery and Corruption policies detail our zero-tolerance approach to any form of slavery or trafficking in our supply chains or any part of our business. We operate an open culture which encourages our employees to raise any issues or concerns in respect of slavery and human trafficking at the earliest opportunity.

CONTRACTUAL CONTROLS AND DUE DILIGENCE
Our zero-tolerance position in relation to slavery and human trafficking is further supported through our continued objective to incorporate suitable provisions within our Supplier contracts. We will continue to review both future and current Supplier contracts and, where appropriate, strengthen their terms to further limit the likelihood of slavery or human trafficking occurring in our supply chains or any part of our business.

We adopt a risk-based approach to due diligence and have been working on adapting and enhancing our due diligence processes on a range of issues, including modern slavery and human trafficking, prior to entering into a relationship with any Supplier who may be considered high risk and/or operates in a higher risk region(s). We have in place a Supplier Code of Conduct asking our Suppliers for commitment and their support in four key areas; Putting Safety First, Environmental Responsibility, Social Responsibility and Conducting Business with Integrity and Fairness. 

We have an Environment and Social Governance (ESG) Colleague Code of Conduct. All Menzies Distribution Group colleagues must acknowledge the significance of social, environmental and ethical trading matters in their conduct, and to work tirelessly towards improving our standards and performance in these areas. 

We continue to monitor the effectiveness of our approach to modern slavery through regular review of our policies, supplier onboarding procedures, contractual arrangements, training programmes and risk assessment processes. The business is committed to continuous improvement and will continue to develop and strengthen its controls as appropriate.

RESPONDING TO CONCERNS AND REMEDIATION
Where actual or suspected instances of modern slavery are identified, we will investigate promptly and proportionately. Our approach is intended to be victim-focused and risk-based. Depending upon the 4 Modern Slavery and Human Trafficking Statement 2025 circumstances, actions may include engagement with suppliers, corrective action plans, enhanced monitoring, referral to appropriate authorities and, where necessary, termination of business relationships.

We recognise that immediate termination may not always be the most effective means of protecting affected individuals and will seek, where appropriate, to work with relevant stakeholders to support sustainable remediation outcomes.

TRAINING
All employees are required to undertake online anti-slavery and human trafficking training through our learning management system on an annual basis. This has and will continue to reinforce the behaviours we expect of all our employees, the repercussions of failing to adhere to such standards and the steps employees should follow to report potential breaches of our policies. All new employees will also be required to undertake this training as part of their onboarding process. 

Completion of training is monitored and reported. Additional targeted training may be provided to employees operating in procurement, operational management, recruitment, human resources and other functions exposed to heightened modern slavery risk.

MEASURING PERFORMANCE
We have continued to monitor our progress in preventing slavery and human trafficking through our due diligence processes for new suppliers and our contract review process for suppliers. Our aim in 2026 is to streamline all Menzies Distribution Group Company Policies and ensure full compliance with all implemented policies. We wish to ensure consistently high standards are applied when undertaking risk assessments and due diligence across our organisation and will continue to work on improving these processes. 

We have separate policies against child labour and forced labour as an expression of our commitment and expectations we have for Suppliers worldwide. We also have a freedom of association policy for our employees. We are committed to creating an ethical workplace, both in terms of how we treat our employees, how our employees treat our customers, our Suppliers and also how we operate within the community. 

As noted, we will continue to keep our supply chains under review to identify and monitor ongoing and future risks. Drawing on best practice, regulatory requirements and industry guidance which may develop, we will seek to strengthen our measures to detect and prevent slavery and human trafficking taking place in our supply chains or any part of our business.

BOARD APPROVAL
This slavery and human trafficking statement for the financial year ending 31 December 2025 has been approved by the Board of Menzies Distribution Services Limited and signed by Richard Morson, Chief Executive Officer.