MODERN SLAVERY POLICY

Introduction

Dale Farm is committed to eliminating the risk of modern slavery and human trafficking throughout the business operations and the supply chain and we are also committed to acting ethically and with integrity in all our business operations and relationships. Modern Slavery and Human Trafficking are unacceptable practices exploiting the most vulnerable people in society. Dale Farm actively supports efforts to eradicate such practices.

Dale Farm Business

Dale Farm is Northern Ireland’s leading dairy company owned by a cooperative of 1,300 dairy farmers and employing more than 1,200 people across our manufacturing facilities in Northern Ireland (Pennybridge Dairy, Ballymena; Dromona Creamery, Cullybackey; Dunmanbridge, Cookstown; Mullins Ice Cream, Kilrea; United Feeds in Belfast and Dungannon), and Wales (Wrexham). We are proud of our heritage and our extensive range of high quality, nutritional products including milk, cream, cheese, ice cream, butters and spreads, available worldwide.

Scope

This is a Group statement and covers the following businesses/business subsidiaries:

Dale Farm Limited

Dale Farm Dairies (Ireland) Limited

Dale Farm Cooperative Ltd

Dale Farm GB Limited

Dale Farm Ice Cream Limited

Dale Farm Ice Cream (Ireland) Limited

Ash Manor Cheese Company Limited

United Feeds Limited

Mullins Ice Cream Limited

Our Commitment

Dale Farm adopt a zero-tolerance approach towards modern slavery and human trafficking including the use of; forced, bonded, indentured or involuntary labour in our own operations or in any activities connected with the Group. Dale Farm is committed to acting responsibly and in the interest of all our stakeholders.

In keeping with the United Nations’ Guiding Principles on Business and Human Rights, which are the fundamental principles and rights at work developed by the International Labour Organisation, Dale Farm is committed to the principles of respect, diversity, fair treatment, fair pay, compensation and benefits and acquisition practices.

We are committed to working with our suppliers in accordance with our objectives in areas of compliance, performance, risk management, social responsibility and governance to maintain transparent and long-term relationships with suppliers. We audit our suppliers on their compliance and against our supply chain standards and we work with them to improve where they fall short.

Our Policies

All employees, agents and anyone acting on Dale Farm’s behalf must comply with company policies and procedures in particular:

Human Rights Policy

This policy highlights Dale Farm’s commitment to managing its business in

accordance with its values to eradicate:

Whistleblowing

This policy enables employees (and others), either anonymously or not, to report breaches or potential breaches without fear of retaliation and is available twenty-four hours a day, seven days a week.

Anti-Corruption & Bribery Policy

This policy aims to prevent any instances of bribery and corruption and strictly forbids any employee, consultant, agency worker, agent, or any other person connected to its business from offering or receiving any reward that may amount to a bribe.

Terms of Supply

Under this responsible sourcing procedure, we will not work with suppliers who do not share our values in respecting human rights and our commitment to eliminating human slavery and human trafficking.

Modern Slavery Policy

This policy reiterates our commitment to eradicating modern slavery and human trafficking and outlines internal measures and checks taken to do this.

Training and Communication

Dale Farm ensure all management, trade union officials and employees receive training in Modern Slavery and are aware of the warning signs so they may react and report appropriately.

Our policies are available to employees and are regularly reviewed and updated as required for any relevant changes.

This statement is published and available on our website at www.dalefarm.co.uk and is communicated to our suppliers.

Due Diligence and Risk Assessment

Our employees and business operations are governed by the Ethical Trading Initiative (ETI) base code, founded on the conventions of the International Labour Organisation and is an internationally recognised code of labour practice. This code outlines legal and ethical responsibilities and Dale Farm are committed to working within this code.

Supply Chain

Dale Farm source raw materials from numerous suppliers around the world and is committed to only working with suppliers who share our commitment to eradicating modern slavery and human trafficking. We will not tolerate any modern slavery or human trafficking in the supply chain, and we will measure the suppliers’ performance in relation to this.

We identify and mitigate risk by conducting audits of our suppliers and potential suppliers on a regular basis to assess and monitor potential risk areas.

Monitoring Performance

Dale Farm use independent social and ethical compliance audits of our facilities to ensure that forced or involuntary labour does not exist. Dale Farm is a member of SEDEX (Supplier Ethical Data Exchange), an ethical supply chain database.

Our operations are audited against ethical and human rights standards on a risk-based frequency usually in the form of a SMETA audit (SEDEX Member Ethical Trade Audit) based on the ETI base code and UK local laws.

Our culture of openness and transparency is vital in helping us to ensure we do not have any ethical or human rights related issues at our production facilities.

It is essential that we continuously identify risks, areas for improvement, and implement actions. We recognise that modern slavery is a complex area and to mitigate risks in this area we will:

Dale Farm is committed to reviewing the effectiveness of our current policies and procedures and is focused on improving our measures to assess the management of the risks that are identified.

Remediation Processes

Our Human Rights and Whistleblowing policies ensure that our employees are afforded the opportunity to report actual or potential issues and they outline the process for doing so. Protection is also given to employees for raising any such issues.

This statement is made in accordance with Section 54 (1) of the Modern Slavery Act 2015 and refers to the financial year ending April 2025.