Our Policies

Anti-Slavery and Human Trafficking Statement

The following statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and
constitutes Whyte and Mackay Group Limited’s slavery and human trafficking statement for the
financial year ending 31 December 2020.

Organisation

Whyte and Mackay Group Limited, a company registered in Scotland (SC221954), is home to an
award-winning collection of Single Malt Whisky. Whyte and Mackay produce a portfolio of premium
spirits in Scotland that are enjoyed around the world. We are the fifth largest Scotch whisky
manufacturer in the world, with products distributed in over 100 countries.

Whyte and Mackay are headquartered in the heart of Glasgow, employing over 560 people and
operating 8 sites across Scotland, including Production, Supply Chain, Distribution, our 5 distilleries,
and a state-of-the-art bottling plant.

Whyte and Mackay are a wholly owned subsidiary of Emperador UK Limited which in turn is wholly
owned by Philippines based Emperador Inc.

Responsibilities

The Chief Executive Officer and Executive Team are responsible for ensuring the statement is up to
date and accurately reflects the Company’s actions and initiatives to tackle slavery and human
trafficking.

HR are responsible for introducing policies and reviewing the process by which they are adopted.
All employees are encouraged to report any concerns they may have, and management are required
to act upon them with appropriate urgency.

Supply chains

Whyte and Mackay are committed to ensuring there is no modern slavery or human trafficking within
its supply chains or in any part of its business. We strive to implement and enforce effective systems
and controls to ensure slavery and human trafficking is not taking place within any of our supply chains.

Having previously introduced a Supplier Declaration Document, requesting current suppliers to confirm
action taken within their organisation in relation to the prevention of modern slavery within their
business and supply chains, this document now forms part of our new supplier onboarding tool. A
policy statement is also now being incorporated into all new supplier agreements.

Due Diligence

Whyte and Mackay will not knowingly support or deal with any business or organisation involved in
slavery or human trafficking. We have undertaken a risk assessment of our global supply chains,
identifying where they extend into sectors and territories that are higher risk in terms of the potential
presence of slavery and human trafficking. As part of our ongoing due diligence we continually seek
to identify any possible risks in these areas and take appropriate corrective action.

When recruiting we adopt good practice approaches to identification and reference checking and as
standard, we require our agency providers to do likewise.

Managing risk

We ensure that the requirements of the Modern Slavery Act 2015 are reflected within our policies and
procedures. We operate the following compliance policies: Preventing Hidden Labour Exploitation,
Whistleblowing, Anti- Corruption & Bribery Policy, Bully and Harassment.

Training and Awareness

A key part of Whyte and Mackay’s modern slavery and human trafficking risk mitigation strategy is to
promote a high level of understanding and awareness of the risks through training and employee
communication.

We continue to provide Modern Slavery Training and awareness programmes across all functions
within Whyte and Mackay to ensure everyone understands the risks and how to report any concerns.

Performance Measures

Whyte and Mackay do not have designated key performance indicators against slavery and human
trafficking. However, we will continue to monitor the effectiveness of our compliance regime and take
necessary steps to strengthen it as appropriate.

Downloads
Whyte & Mackay Anti-Slavery and Human Trafficking Policy
Download a copy of our Anti-Slavery and Human Trafficking Policy