Modern Slavery and Human Trafficking Statement

Carnaby Caravans Ltd has taken steps to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.

In accordance with Section 54, Part 6 of the Modern Slavery Act 2015 (the Act), this statement sets out the steps that Carnaby Caravans Ltd has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.

Our organisation structure and supply chains

Carnaby Caravans Ltd are a manufacturer of caravan holiday homes which distributes its products through dealers and direct to holiday parks in the UK and EU countries. Carnaby Caravans Ltd has a number of long- established preferred suppliers. We consider the biggest exposure to modern slavery is through our supply chain. Most components are bought directly from UK suppliers, although some suppliers source indirectly from overseas.

New suppliers are subject to appropriate due diligence before permitting them to supply or become a preferred new supplier. This due diligence may include:

• Vetting of supplier’s businesses, assessing associated risk, and ascertaining the supplier’s modern slavery policies
• Undertaking online searches to ensure that the organisation has never been convicted of offences relating to modern slavery.
• Visiting supplier’s premises, observing, and monitoring working conditions.

Ongoing due diligence is undertaken through regular review of our supply chain to ensure that all suppliers are compliant with the modern-day slavery act. If we find breaches of these laws within our supply chain, we will look to support companies in their efforts to comply with the legislation. If corrective action is not promptly implemented, we will consider our future with the supplier.

Our policies in relation to the Modern Slavery Act 2015

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

We do not enter business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

Responsibility for enforcing our Anti-slavery policy rests ultimately with the Board of Directors who manage this responsibility in the following ways:

• Carnaby Caravans Ltd has an Anti-Slavery Policy. All staff in positions of responsibility which might carry a risk of contact with Modern Slavery and Human Trafficking are briefed on this policy.
• Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.
• providing awareness training, where appropriate, to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking.
• ensuring Carnaby Caravans Ltd procurement strategies include references to modern slavery and human trafficking.
• continuing to take action to embed a zero-tolerance policy towards modern slavery.

This statement is in respect of the financial year ended 31st October 2023 and was approved by the board of directors 18th March 2024.