PGI Group Ltd - Modern Slavery and Human Trafficking Statement

Statement of compliance for the year ended 31 December 2022

This statement is made pursuant to section 54, Part 6 of the Modern Slavery Act 2015 (the “Act”) and sets out the steps that each of PGI Group Ltd (the “Company”) and its subsidiaries (together the “Group”) has taken and will be taking to ensure, as far as possible, that modern slavery and human trafficking is not taking place either within that Group company or in the supply chains of its businesses.

PGI Group Ltd is a UK based ultimate holding company that has locally incorporated subsidiaries that operate businesses in Malawi, Zambia and Zimbabwe in Southern Africa. These subsidiaries operate both farms and processing factories that produce tea, roses and macadamia nut kernels and generate electricity from hydroelectric & solar power schemes, which transmit electricity into the national grids of Zimbabwe and Malawi.

For many years Group companies have worked hard to ensure that the wider communities in which they each operate benefit from relevant Group company actions through development projects in water & sanitation, education, health and, more recently, in extending the electricity grid to their villages. Consistent with the Group’s commitment to high legal and ethical standards, no company within the Group permits slavery, forced labour, child labour, or any use of force or coercion in its operations.

Responsibility for legal and ethical compliance is devolved to the leadership of each Group company to ensure it has systems and processes in place to address such risks in its operations. Local management in each Group company regularly undertakes internal checks and assessments to satisfy themselves that there is no slavery or human trafficking taking place within the businesses and reports as to whether employee standards are being implemented and upheld. Employees throughout the Group are encouraged to speak freely without fear of reprisal, and this is supported by employee whistleblowing policies.

Each Group company complies with the employment laws of the countries in which it operates and works with suppliers and businesses that do the same. Each Group company also aims to provide higher standards for its employees than those required by local labour laws and seeks to improve upon them by implementing labour and social standards emanating from external accreditation bodies, which include Ethical Tea Partnership, Rainforest Alliance, Fairtrade and MPS-ECAS. These bodies require an audit of the relevant Group company's employment practices as part of maintaining the accreditations.

A significant part of the Malawi company’s tea supply chain involves the purchasing of green tea from smallholder growers (tier one suppliers). These are typically very small family businesses operating at a subsistence level. This subsidiary’s business could pose a heightened risk of linkage to modern slavery. To mitigate this, the subsidiary works with smallholders that comply with all local labour laws and are accredited to the international standards of both Fairtrade and Rainforest Alliance, each of whom require regular audits to maintain accreditation.

The Company itself has only limited direct supply chains which are predominantly in the UK. The goods and services the Company purchases primarily relate to professional services, travel and office costs.

It is recognised that there may always be risks of linkage to modern slavery in the countries in which the Group is invested, but to mitigate the risks, each Group company aims to carry out the following, as far as resources permit:
▪ Ensuring as far as possible that its expectations are clearly communicated regarding compliance with the Modern Slavery Act 2015 to the tier one suppliers and contractors with which it deals
▪ Monitoring potential risk areas in its tier one supply chains on an on-going basis, which is carried out by its local management teams
▪ Inclusion of modern slavery as part of its external accreditation audit scope
▪ Training to increase awareness and understanding of the scope of modern slavery

This statement was approved by the Board of PGI Group Ltd on 21 June 2023 and the original has been signed by Margaret Gage, Finance Director on 21 June 2023.