Modern slavery and human trafficking statement 2025

ROBIN BIRLEY HOLDINGS

This statement is published in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps taken by Robin Birley Holdings Limited and its UK subsidiaries (5 Hertford Street Trading Limited, Winter Restaurants Limited, Birley Pastry Limited and Sicasa Limited) during the year ended 31 December 2025.

INTRODUCTION

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 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.

This statement highlights the key activities we have undertaken to combat modern slavery in our organisation.

GROUP COMPANIES

Robin Birley Holdings is a group of businesses dedicated to ethical practices across various sectors:

  1. 5 Hertford Street Trading Limited t/a 5 Hertford Street: A private members’ club offering dining, entertainment, and social events. Its activities include the operation of restaurants, bars, and event spaces, together with the provision of hospitality services to members and their guests.
  2. Winter Restaurants Limited t/a Oswald’s: A private members’ club providing fine dining and social facilities. Its activities include the operation of a restaurant, bar, and event spaces, as well as hosting member functions and private events.
  3. Birley Pastry Limited t/a Birley Bakery: A bakery business supplying baked goods. Its activities include the production of bakery products, and direct sales to customers.
  4. Sicasa Limited t/a Birleys: A business specialising in freshly prepared sandwiches and light meals. Its activities include the preparation and sale of sandwiches, salads, and related products.

OUR SUPPLY CHAINS

In order to ensure our suppliers, understand our approach to compliance within the supply chain, including but not limited to our policies on antibribery and modern slavery, we incorporate specific compliance clauses into our supplier contracts and our Terms and Conditions of Purchase. These contractual provisions require suppliers to adhere to our standards and to notify us of any issues of noncompliance. Where a supplier is unable to comply, we will review the reasons provided and work with them towards achieving full compliance or consider whether continuation of the relationship is appropriate.

Our suppliers operate across a range of industries, including hospitality. The majority are based in the United Kingdom, Europe, or the United States.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We review and update all our policies.

Our Anti-slavery 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 anywhere in our supply chains. Our Policy is addressed 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. We also have the following policies in place relevant to modern slavery, which we continuously review and update:

  • Whistleblowing Policy - We encourage all employees and suppliers to report any concerns related to modern slavery through our confidential whistleblowing procedure.
  • Regulated working hours – All our employees must adhere to variations of working hours but the hours will always be subject to the requirements of the Working Time Regulations 1998.
  • Equal Opportunity Policy – We promote fair treatment of employees, by reducing vulnerability to exploitation. This safeguards against discriminatory practices that can enable forced labour.
  • Harassment and Bullying Policy – We protect employees from coercion and abuse, which can often be linked to exploitative labour conditions.
  • Supplier Code of Conduct - All our suppliers are required to adhere to our Supplier Code of Conduct, which explicitly prohibits the use of forced, bonded, or involuntary labour, child labour, and human trafficking.

We provide safe working environments, offer grievance mechanisms, and conduct right-to-work checks. These policies apply across all Robin Birley Holdings entities and are regularly reviewed for effectiveness.

SUPPLIER CODE OF CONDUCT

We have implemented a Supplier Code of Conduct that clearly communicates our social standards and business ethics to our supply chain. This code includes specific requirements directly relevant to preventing Modern Slavery within our suppliers' businesses.

All new and existing suppliers are made aware of our Supplier Code of Conduct and asked to confirm their adherence.

DUE DILIGENCE PROCESSES FOR MODERN SLAVERY

We evaluate our suppliers across quality, ethics, and risk metrics. As part of our initiative to identify and mitigate risk we undertake the following due diligence processes:

  1. Identify and assess potential risk areas in our supply chains: We conduct regular risk assessments of our supply chains to identify areas of high risk for modern slavery. This includes evaluating the geographic locations and sectors of our suppliers.
  2. Mitigate the risk of slavery and human trafficking occurring in our supply chains.
  3. Monitor potential risk areas in our supply chains.
  4. Supplier Onboarding: All new suppliers undergo a thorough due diligence process, including a review of their ethical practices and a commitment to adhering to our Supplier Code of Conduct.
  5. Supplier Audits: We perform periodic audits of our suppliers, including on-site visits and assessments of their labour practices and compliance with our Supplier Code of Conduct.
  6. Protect whistle blowers.

FURTHER STEPS

Robin Birley Holdings Limited continues to work with our suppliers to increase supply chain transparency and more specifically in relation to ensuring Modern Slavery is not taking place within its supply chain.