Modern Slavery Statement
Modern Slavery Statement
Statement of compliance for the year to 31 December 2025
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (Act) and is published by Camellia Plc (Camellia). It sets out the steps Camellia has taken to prevent slavery, human trafficking and forced labour in its own supply chains as well as Camellia's expectations of, and steps being taken by, the operating companies in which it is invested.
Overview of our business and our policy
Camellia is the ultimate holding company of a diverse group of companies (Group). Within the Group, Camellia has indirect interests in several entities which have responsibility for managing primarily agricultural operations, including responsibility for managing the assets and employees associated with those operations (operating companies), as well as other investments. The operating companies are based in Bangladesh, Brazil, India, Kenya, Malawi, South Africa, Tanzania and the UK. The majority of the Group’s turnover is derived from the work carried out by the operating companies in the agricultural sector through the growing of tea, avocado, macadamia, rubber, wine grapes, blueberries, arable crops, forestry and livestock farming.
Consistent with the Group's long-standing commitment to maintaining high legal and ethical standards, slavery, human trafficking and forced labour in any form are prohibited in the business and operations of all operating companies.
Governance and strategy
Camellia's business philosophy is based on an approach which provides the operating companies with a high degree of operational autonomy. This is founded on a belief that the management teams of the individual operating companies have better local insight and expertise which positions them to make better decisions with respect to operational matters, employees, local communities and the environment. So that Camellia can have confidence that this operational autonomy is being exercised consistent with its expectations of legal and ethical compliance, those expectations are set out within Camellia’s Group Guiding Principles which detail the principles that Camellia expects the operating companies to adopt and adhere to in key areas such as human rights, anti-bribery and corruption, environmental, certification and traceability, employee welfare, health and safety and whistleblowing.
From a modern slavery and human rights perspective, those expectations have been set by the Camellia Board, with the support of its Sustainability and Safeguarding Committee. For more information, visit the Corporate Governance section of the Camellia website.
Responsibility for achieving legal and ethical compliance in accordance with the Group Guiding Principles (as well as local laws and regulations) lies with the leadership and the boards of directors of the respective operating companies. Operating companies are responsible for developing local policies and procedures that support the welfare of the communities and the environments in which they operate (including in relation to slavery, human trafficking and forced labour) and that strive to create safe working environments in which all employees and other stakeholders are treated fairly and with respect.
Ultimately, those individual operating companies have the local expertise and understanding which means they are best placed to identify relevant needs and apply the processes and practices that allow them to operate legally, responsibly and ethically over the long term and to embed the expectations set out in the Group Guiding Principles into their own culture, strategy and daily practices. For the same reason, the operating companies are also bestplaced to implement and monitor compliance with the policies and practices that they put in place. This promotes the continuity, development and progressive growth of those individual enterprises in an ethical and responsible way, that is relevant to, and supportive of, their own local jurisdictions and cultures.
For further information on the Group Guiding Principles, please refer to the Corporate Governance section of the Camellia website.
Operations and supply chain risks
It is recognised that modern slavery exists in many different forms and can be difficult to detect, particularly in complex international supply chains. Camellia itself is a UK holding company with limited direct supply chains. Those supply chains are predominantly in the UK, and generally low risk in nature. The goods and services Camellia purchases to deliver its services primarily relate to information technology, professional services, travel, catering, property, facility management, maintenance and other materials as required.
The operating companies have more involved risks within both their own direct operations and their local supply chains. Although a number of the operating companies' employees are permanent, as is common in the agricultural sector, it is often necessary to employ seasonal employees in various jobs. Although the operating companies seek to pay wages, benefits and allowances in accordance with local legislation and trade union agreements, generally speaking the nature of a seasonal workforce has the ability to give rise to various heightened risks. We therefore expect that additional controls and mitigations are adopted by those operating companies where appropriate, locally. We note that many of the operating companies have received and maintain certifications with challenging ethical standards from, inter alia, SMETA-ETI, GLOBALG.A.P., Trustea and Rainforest Alliance, which reflect these operating companies' commitment to high standards in this area. The certifications require detailed social performance audits, including of employment practices in the operating companies and of key suppliers.
The majority of the tier one suppliers for the agricultural operating companies are smallholder farmers. The operating companies purchase products from these growers at a market-related price which they then process, pack and sell via their own channels to market. Many of the operating companies have established extension service programs to support local smallholder farmers, assisting them with their farms and crops and helping to build closer relationships. Most operating companies have a continuous process of engagement with their considerable number of tier one suppliers to understand supply chain risks. Identifying these risks and establishing practical mitigation measures is an evolving process which requires both short and long-term strategies.
The operating companies are responsible for implementing their own due diligence and onboarding measures in relation to their suppliers. These include conducting supply chain due diligence on their major tier one and tier two suppliers, where feasible, and including enhanced contractual protections as necessary in relation to modern slavery and human trafficking matters.
Supply chain standards
Whilst neither Camellia nor the operating companies can guarantee that all tiers within their respective supply chains are completely free of slavery, human trafficking or forced labour, as customers the operating companies are expected to play an active role in communicating their expectations to chart a journey of continuous improvement.
In that context, the operating companies continue their efforts to grow and nurture their businesses, including developing relationships with various stakeholders, in a sustainable way with respect to human rights as defined by the UN Guiding Principles on Business and Human Rights. For example, certain operating companies have in place specific policies and procedures relating to ethical purchasing designed to mitigate risks to people.
Training
Camellia has undertaken and continues training of its directors and relevant employees in relation to modern slavery. Likewise, where relevant, the operating companies have undertaken and continue training of their relevant employees and, where appropriate, suppliers to raise awareness of modern slavery issues and assist in identifying risks in their given businesses and supply chains.
Monitoring and reporting of concerns
The Camellia Board, together with and supported by the Group General Counsel and the Sustainability and Safeguarding Committee, will:
- continue to oversee the implementation and monitoring of Camellia plc’s compliance with the Act in respect of its own operations and supply chains; and
- in accordance with the governance approach described above, keep under review the alignment of the operating companies with the Group
Guiding Principles.
The leadership of the individual operating companies is responsible for overseeing compliance with legal and ethical requirements relating to slavery, human trafficking and forced labour in their business and jurisdictions, in line with the Group Guiding Principles. This includes having and maintaining appropriate remediation and redress mechanisms.
We also expect that any modern slavery issues identified by employees, officers, consultants, contractors, volunteers, interns, casual workers, agency workers and the general public can, and should be, immediately reported to the appropriate point of contact in the relevant operating company in line with the Whistleblowing Group Guiding Principles as implemented and operationalised locally.
Next steps
This MSA statement will be posted on the UK Government's Modern Slavery registry. Camellia has also registered its nominated contact on such registry.
Continued training of Camellia's key personnel.
Operating companies to continue periodic business reviews to assess compliance in their operations, including undertaking further supply chain due diligence and related mitigating measures in respect of key tier one and two suppliers. Operating companies to promote further training of the smallholders and outgrowers where relevant.
Board approval
This statement was approved by the Board of Camellia Plc on 30 April 2026
Next Review: April 2027
Name: Simon Turner
Title: Chairman
Date: 30 April 2026