Slavery and Human Trafficking Statement for the financial year 1st November 2024 to 31st October 2025

Introduction

EBC Holdings Limited and its subsidiaries Freeman Automotive (UK) Limited, European Friction Industries Limited, EBC Brakes Direct Limited, A C Freeman Investments Limited) and EBC Brakes USA Inc are committed to ensuring that modern slavery and human trafficking do not take place within our businesses or supply chains. We recognize our responsibility to uphold the highest standards of integrity and ethical conduct in all our operations.

Our Commitment

We are dedicated to maintaining a work environment that respects human rights and promotes fair labour practices. This statement outlines the steps we have taken and will continue to take to prevent modern slavery and human trafficking within our business
operations and supply chain.

Policies

1. Code of Conduct: Our Code of Conduct explicitly prohibits any form of forced labour, child labour, or human trafficking. All employees, suppliers and partners are required to adhere to these standards.

2. Supplier Code of Conduct:We expect our suppliers to share our commitment to ethical practices. Our Supplier Code of Conduct mandates compliance with all applicable labour laws, including those related to modern slavery and human trafficking.

3. Whistleblower Policy: We encourage employees, suppliers, and other stakeholders to report any concerns related to modern slavery. Reports can be made anonymously and without fear of retaliation.

Due Diligence Processes

We have implemented robust due diligence processes to identify and mitigate risks related to modern slavery:

Employees Right to Work Checks - These are completed for all employees working for the organization in accordance with current legislation and guidance issue by the Home Office and we will only employ individuals who have provided documentary evidence that they legally have the right to work in the UK.

Training and Awareness

We believe that education is key to preventing modern slavery. We provide regular training to our employees on identifying and addressing risks related to modern slavery and human trafficking. This includes:

1. Employee Training: Regular training sessions for employees, particularly those in procurement and supply chain management, to recognise the signs of modern slavery and understand the steps to take if they suspect an issue.

Monitoring and Reporting

We continually monitor the effectiveness of our efforts to combat modern slavery through:
1. Regular Reviews:Annual reviews of our policies and procedures to ensure they remain effective and up to date.

Conclusion

Modern slavery is a heinous crime that we are committed to eradicating from our business and supply chains. We will continue to work diligently to uphold human rights and promote ethical labour practices in all our operations. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes EBC Holdings Limited's modern slavery and human trafficking statement for the financial year ending 2025.

Director approval

This statement has been approved by the Group CEO of EBC Holdings Limited.

James Hallett
Chief Executive Office
Date:2nd April 2025