Modern Anti-Slavery Policy

Introduction from the CEO: Chris Hopkins

We are proud of the steps we have taken to combat slavery and human trafficking. We have instituted a wide-ranging Anti-Slavery and Human Trafficking Policy (“ASHT Policy”) applicable both to our employees and to all levels of our supply chain. It is critical that everyone at Turnbull & Co keeps a sharp focus on identifying and reporting any concerns in this respect in accordance with our ASHT Policy.

Organisation’s Structure

We are a supplier of goods and materials in the builders’ merchant sector. Our ultimate parent company is Hopkins Group Limited. We have over 200 employees and operate both online and through a number of branches around the United Kingdom.

In the last financial year, we had an annual turnover of £62 million.

Our Supply Chains

The vast majority of our suppliers are sourced via the Fortis Merchant Network (“Fortis”), a leading independent mixed merchant buying group. Fortis places a strong emphasis on corporate conscience as part of its criteria for membership, which is a natural fit for our business goals as set out in our ASHT Policy.

Our Policy on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our ASHT Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place any where in out supply chains.

A copy of our ASHT Policy is available for reference purposes.

Supplier Adherence to our Value and Ethics

As part of our initiative to identify and mitigate risk we have incorporated our ASHT policy into our contractual relationship with all suppliers.

When assessing both current and potential future suppliers, we endeavour to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to appropriate members of our staff.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31/12/23.