MODERN SLAVERY STATEMENT

BRUCOM DISTRIBUTION LTD 

Modern Slavery and Human Trafficking Statement 

For the Financial Year Ending 30 November 2026 

Issued in accordance with the Modern Slavery Act 2015 

1.0 Purpose

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. It outlines the steps Brucom Distribution Ltd has taken and is continuing to take to ensure that modern slavery or human trafficking is not occurring in our business operations or within our supply chain. 
Modern slavery includes slavery, servitude, forced or compulsory labour, and human trafficking—all of which we consider fundamentally unacceptable. Brucom maintains a zero-tolerance policy towards modern slavery in any form and is committed to acting ethically and with transparency in all business dealings.

Brucom Distribution Ltd is a UK-based, world-class manufacturer of electrical systems and assemblies. We supply global markets across the following sectors: 

• Automotive 
• Defence 
• Industrial 
• Manufacturing 
• Rail 
• Medical 
• Power Generation 

Our operations are based at dedicated manufacturing sites in the United Kingdom, and our workforce is employed in compliance with UK employment law. Brucom is a Living Wage Employer, and we are committed to the well-being of all directly employed and indirectly contracted individuals.

Our highest risk areas in relation to modern slavery lie with raw material suppliers outside of the EU, where regulatory frameworks may be less stringent. To mitigate this risk: 

We only engage with suppliers that meet our supplier criteria and compliance specifications. 

Brucom maintains a supplier evaluation and approval process which includes consideration of ethical sourcing and modern slavery risks where applicable.

Brucom has implemented the following internal policies to prevent and identify modern slavery and human trafficking: 

Anti-Slavery Policy – Outlines our position and provides employee guidance on recognising and reporting concerns. Recruitment Policy – Includes rigorous right-to-work checks to prevent forced or illegal labour practices. 

Whistle-blowing Policy – Ensures that employees can report concerns confidentially and without fear of retaliation. Code of Business Conduct – Defines expected ethical behaviours and standards for all employees and suppliers.

We maintain a preferred supplier list and carry out due diligence before any organisation is approved, which may include: 

Online investigations into legal and ethical records. 

On-site audits focusing on working conditions (as required). 

Requiring supplier acceptance of our Anti-Slavery Policy as part of contractual obligations. 

We further require that all suppliers: 

1. Confirm they have taken steps to eradicate modern slavery within their own operations. 
2. Hold their own suppliers accountable to anti-slavery standards. 
3. (UK suppliers) Pay at least the National Minimum Wage. 
4. (International suppliers) Pay the prevailing minimum wage of their country of operation. 
5. Understand that Brucom reserves the right to terminate contracts if any instance of modern slavery is discovered.

6.0 Training and awareness

Relevant personnel involved in procurement are provided with awareness of modern slavery risks as part of compliance and induction processes.

7.0 Measuring effectiveness

We monitor the effectiveness of our anti-slavery measures using the following indicator: 
No reports of modern slavery from employees, the public, or authorities during the reporting year.