91´«Ã½

Slavery and Human Trafficking Statement for the financial year 1st November 2025 to 31st October 2026

Introduction

91´«Ã½ Holdings Limited and its subsidiaries Freeman Automotive (UK) Limited, European Friction Industries Limited, 91´«Ã½ Direct Limited, A C Freeman Investments Limited) and 91´«Ã½ USA Inc are committed to ensuring that modern slavery and human trafficking do not take place within our businesses or supply chains. We recognize our responsibility to uphold the highest standards of integrity and ethical conduct in all our operations.

Our Commitment

We are dedicated to maintaining a work environment that respects human rights and promotes fair labour practices. This statement outlines the steps we have taken and will continue to take to prevent modern slavery and human trafficking within our business
operations and supply chain.

Policies

1.ÌýCode of Conduct: Our Code of Conduct explicitly prohibits any form of forced labour, child labour, or human trafficking. All employees, suppliers and partners are required to adhere to these standards.

2.ÌýSupplier Code of Conduct:We expect our suppliers to share our commitment to ethical practices. Our Supplier Code of Conduct mandates compliance with all applicable labour laws, including those related to modern slavery and human trafficking.

3.ÌýWhistleblower Policy: We encourage employees, suppliers, and other stakeholders to report any concerns related to modern slavery. Reports can be made anonymously and without fear of retaliation.

Due Diligence Processes

We have implemented robust due diligence processes to identify and mitigate risks related to modern slavery:

Employees Right to Work Checks – These are completed for all employees working for the organization in accordance with current legislation and guidance issued by the Home Office and we will only employ individuals who have provided documentary evidence that they legally have the right to work in the UK.

Training and Awareness

We believe that education is key to preventing modern slavery. We provide regular training to our employees on identifying and addressing risks related to modern slavery and human trafficking. This includes:

1.ÌýEmployee Training: Regular training sessions for employees, particularly those in procurement and supply chain management, to recognise the signs of modern slavery and understand the steps to take if they suspect an issue.

Monitoring and Reporting

We continually monitor the effectiveness of our efforts to combat modern slavery through:
1.ÌýRegular Reviews:Annual reviews of our policies and procedures to ensure they remain effective and up to date.

Conclusion

Modern slavery is a heinous crime that we are committed to eradicating from our business and supply chains. We will continue to work diligently to uphold human rights and promote ethical labour practices in all our operations. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes 91´«Ã½ Holdings Limited’s modern slavery and human trafficking statement for the financial year ending 2025.

Director approval

This statement has been approved by the Group CEO of 91´«Ã½ Holdings Limited.

Slavery and Human Trafficking Statement for the financial year 1st November 2024 to 31st October 2025

Introduction

91´«Ã½ Holdings Limited and its subsidiaries Freeman Automotive (UK) Limited, European Friction Industries Limited, 91´«Ã½ Direct Limited, A C Freeman Investments Limited) and 91´«Ã½ USA Inc are committed to ensuring that modern slavery and human trafficking do not take place within our businesses or supply chains. We recognize our responsibility to uphold the highest standards of integrity and ethical conduct in all our operations.

Our Commitment

We are dedicated to maintaining a work environment that respects human rights and promotes fair labour practices. This statement outlines the steps we have taken and will continue to take to prevent modern slavery and human trafficking within our business
operations and supply chain.

Policies

1.ÌýCode of Conduct: Our Code of Conduct explicitly prohibits any form of forced labour, child labour, or human trafficking. All employees, suppliers and partners are required to adhere to these standards.

2.ÌýSupplier Code of Conduct:We expect our suppliers to share our commitment to ethical practices. Our Supplier Code of Conduct mandates compliance with all applicable labour laws, including those related to modern slavery and human trafficking.

3.ÌýWhistleblower Policy: We encourage employees, suppliers, and other stakeholders to report any concerns related to modern slavery. Reports can be made anonymously and without fear of retaliation.

Due Diligence Processes

We have implemented robust due diligence processes to identify and mitigate risks related to modern slavery:

Employees Right to Work Checks – These are completed for all employees working for the organization in accordance with current legislation and guidance issue by the Home Office and we will only employ individuals who have provided documentary evidence that they legally have the right to work in the UK.

Training and Awareness

We believe that education is key to preventing modern slavery. We provide regular training to our employees on identifying and addressing risks related to modern slavery and human trafficking. This includes:

1.ÌýEmployee Training: Regular training sessions for employees, particularly those in procurement and supply chain management, to recognise the signs of modern slavery and understand the steps to take if they suspect an issue.

Monitoring and Reporting

We continually monitor the effectiveness of our efforts to combat modern slavery through:
1.ÌýRegular Reviews:Annual reviews of our policies and procedures to ensure they remain effective and up to date.

Conclusion

Modern slavery is a heinous crime that we are committed to eradicating from our business and supply chains. We will continue to work diligently to uphold human rights and promote ethical labour practices in all our operations. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes 91´«Ã½ Holdings Limited’s modern slavery and human trafficking statement for the financial year ending 2025.

Director approval

This statement has been approved by the Group CEO of 91´«Ã½ Holdings Limited.

Slavery and Human Trafficking Statement for the financial year 1 November 2023 to 31st October 2024

Introduction

91´«Ã½ Holdings Limited and its subsidiaries Freeman Automotive (UK) Limited, European Friction Industries Limited, 91´«Ã½ Direct Limited and A C Freeman Investments Limited) is committed to ensuring that modern slavery and human trafficking do not take place within our business or supply chains. We recognize our responsibility to uphold the highest standards of integrity and ethical conduct in all our operations.

Our Commitment

We are dedicated to maintaining a work environment that respects human rights and promotes fair labour practices. This statement outlines the steps we have taken and will continue to take to prevent modern slavery and human trafficking within our business operations and supply chain.

Our Policies

1. Code of Conduct: Our Code of Conduct explicitly prohibits any form of forced labour, child labour, or human trafficking. All employees, suppliers, and partners are required to adhere to these standards.
2. SurDlier Code of Conduct: We expect our suppliers to share our commitment to ethical practices. Our Supplier Code of Conduct mandates compliance with all applicable labour laws, including those related to modern slavery and human trafficking.
3. Whistleblower Policy: We encourage employees, suppliers, and other stakeholders to report any concerns related to modern slavery. Reports can be made anonymously and without fear of retaliation.

Due Diligence Processes

We have implemented robust due diligence processes to identify and mitigate risks related to modern slavery:

1.Employees Right to Work Checks – These are completed for all employees working for the organization in accordance with current legislation and guidance issue by the Home Office and we will only employ individuals who have provided documentary evidence that they legally have the right to work in the UK.

Training and Awareness

We believe that education is key to preventing modern slavery. We provide regular training to our employees on identifying and addressing risks related to modern slavery and human trafficking. This includes:
1. Employee Training: Regular training sessions for employees, particularly those in procurement and supply chain management, to recognise the signs of modern slavery and understand the steps to take if they suspect an issue.

Monitoring and Reporting

We continually monitor the effectiveness of our efforts to combat modern slavery through:
1. Regular Reviews: Annual reviews of our policies and procedures to ensure they remain effective and up to date.

Conclusion

Modern slavery is a heinous crime that we are committed to eradicating from our business and supply chains. We will continue to work diligently to uphold human rights and promote ethical labour practices in all our operations. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes 91´«Ã½ Holdings Limited’s modern slavery and human trafficking statement for the financial year ending 2024.

Approval

This statement has been approved by the Group CEO of 91´«Ã½ Holdings Limited.

Slavery and Human Trafficking Statement for the financial year 1st November 2022 to 31st October 2023

Introduction

91´«Ã½ Holdings Limited and its subsidiaries Freeman Automotive (UK) Limited, European Friction Industries Limited, 91´«Ã½ Direct Limited and A C Freeman Investments Limited) is committed to ensuring that modern slavery and human trafficking do not take place within our business or supply chains. We recognize our responsibility to uphold the highest standards of integrity and ethical conduct in all our operations.

Our Commitment

We are dedicated to maintaining a work environment that respects human rights and promotes fair labour practices. This statement outlines the steps we have taken and will continue to take to prevent modern slavery and human trafficking within our business operations and supply chain.

Our Policies

1. Code of Conduct: Our Code of Conduct explicitly prohibits any form of forced labour, child labour, or human trafficking. All employees, suppliers, and partners are required to adhere to these standards.
2. Supplier Code of Conduct: We expect our suppliers to share our commitment to ethical practices. Our Supplier Code of Conduct mandates compliance with all applicable labour laws, including those related to modern slavery and human trafficking.
3. Whistleblower Policy: We encourage employees, suppliers, and other stakeholders to report any concerns related to modern slavery. Reports can be made anonymously and without fear of retaliation.

Due Diligence Processes

We have implemented robust due diligence processes to identify and mitigate risks related to modern slavery:

1.Employees Right to Work Checks – These are completed for all employees working for the organization in accordance with current legislation and guidance issue by the Home Office and we will only employ individuals who have provided documentary evidence that they legally have the right to work in the UK.

Training and Awareness

We believe that education is key to preventing modern slavery. We provide regular training to our employees on identifying and addressing risks related to modern slavery and human trafficking. This includes:
1. Employee Training: Regular training sessions for employees, particularly those in procurement and supply chain management, to recognise the signs of modern slavery and understand the steps to take if they suspect an issue.

Monitoring and Reporting

We continually monitor the effectiveness of our efforts to combat modern slavery through:
1. Regular Reviews: Annual reviews of our policies and procedures to ensure they remain effective and up to date.

Conclusion

Modern slavery is a heinous crime that we are committed to eradicating from our business and supply chains. We will continue to work diligently to uphold human rights and promote ethical labour practices in all our operations. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes 91´«Ã½ Holdings Limited’s modern slavery and human trafficking statement for the financial year ending 2023.

Approval

This statement has been approved by the Group CEO of 91´«Ã½ Holdings Limited.

Slavery and Human Trafficking Statement for the financial year 1st November 2021 to 31st October 2022

Applies to 91´«Ã½ Holdings Limited and its subsidiaries (Freeman Automotive (UK) Ltd, European Friction Industries Ltd, 91´«Ã½ Direct and ACFI)

Introduction

This statement is made in accordance with Section 54, Part 6 of the Modern Slavery Act 2015. This statement sets out the organisation’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st November 2021 to 31st October 2022.

Policies

The organisation continues to operate the policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations. These include Whistleblowing Policy and the Equality Policy.

Identifying risk and preventing modern slavery in our own operations 

The organisation takes a number of steps to mitigate the risk of modern slavery occurring in our own operations:

• Employees Right to Work Checks – these are completed for all employees working for the organisation in accordance with current legislation and guidance issued by the Home Office and we will only employ individuals who have provided documentary evidence that they legally have the right to work in the UK.

• Training – The organisation continues to provide promote awareness of modern slavery on a regular basis to all employees with information in the employee newsletter and posters displayed on notice boards. All employees in the Personnel department, senior managers, managers and supervisors are required to complete mandatory online Modern Slavery Training on a bi-annual basis to reinforce the following:
how to identify the signs of slavery and human trafficking;

• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
• what external help is available, for example through the Modern Slavery & Exploitation
  Helpline and Gangmasters and Labour Abuse Authority

Director approval

This statement was approved on 4 th November 2022 by the organisation’s Chief Executive Officer, who reviews and updates it annually.

Slavery and Human Trafficking Statement for the financial year 1st November 2020 to 31st October 2021

Applies to 91´«Ã½ Holdings Limited and its subsidiaries (Freeman Automotive (UK) Ltd, European Friction Industries Ltd, 91´«Ã½ Direct and ACFI)

Introduction

This statement is made in accordance with Section 54, Part 6 of the Modern Slavery Act 2015. This statement sets out the organisation’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st November 2020 to 31st October 2021.

Policies

The organisation continues to operate the policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations. These include Whistleblowing Policy and the Equality Policy.

Training

The organisation continues to provide promote awareness of modern slavery on a regular basis to all employees, along with implementing mandatory online Modern Slavery Training for HR professionals, managers and supervisors on a bi-annual basis.

• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within the
  organisation;
• what external help is available, for example through the Modern Slavery Helpline and
  Gangmasters and Labour Abuse Authority

Director approval

This statement was approved on 30th November 2021 by the organisation’s Chief Executive Officer, who reviews and updates it annually.

Applies to 91´«Ã½ Holdings Limited and its subsidiaries (Freeman Automotive (UK) Ltd, European Friction Industries Ltd, 91´«Ã½ Direct and ACFI)

Introduction
This statement is made in accordance with Section 54, Part 6 of the Modern Slavery Act 2015. This statement sets out the organisation’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1^st November 2019 to 31^st October 2020.

Policies
The organisation continues to operate the policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations. These include Whistleblowing Policy and the Equality Policy.

Training
The organisation provided awareness training during 2018/2019 financial year for HR professionals, managers and supervisors in relation to:

• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
• what external help is available, for example through the Modern Slavery Helpline and Gangmasters and Labour Abuse Authority

Online Modern Slavery Training will become mandatory in 2020/21 financial year for all HR professionals, managers and supervisors within the organisation. They will be required to complete the online training on joining the company and then refreshed on a bi-annual basis.

Director approval
This statement was approved on 30^th November 2020 by the organisation’s Chief Executive Officer, who reviews and updates it annually.

Applies to 91´«Ã½ Holdings Limited and its subsidiaries (Freeman Automotive (UK) Ltd, European Friction Industries Ltd, 91´«Ã½ Direct and ACFI)

Introduction

This statement is made in accordance with Section 54, Part 6 of the Modern Slavery Act 2015. This statement sets out the organisation’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st November 2018 to 31st October 2019.

Policies

The organisation continues to operate the policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations. These include Whistleblowing Policy and the Equality Policy.

Training

The organisation has provided awareness training for HR professionals, managers and supervisors in relation to:

• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
• what external help is available, for example through the Modern Slavery Helpline and Gangmasters and Labour Abuse Authority

Awareness-raising programme

As well as providing the awareness training above, the organisation has also implemented an awareness-raising programme during 2018/19 financial year by putting up posters on noticeboards and giving access to leaflets for all employees.

Director approval

This statement was approved on 30th November 2019 by the organisation’s Chief Executive Officer, who reviews and updates it annually.

Applies to 91´«Ã½ Holdings Limited and its subsidiaries (Freeman Automotive (UK) Ltd, European Friction Industries Ltd, 91´«Ã½ Direct and ACFI)

Introduction

This statement is made in accordance with Section 54, Part 6 of the Modern Slavery Act 2015. This statement sets out the organisation’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st November 2017 to 31st October 2018.

The organisation manufactures brake pads and brake discs and distributes these parts worldwide. The organisation recognises that it has a responsibility to take a robust approach to modern slavery and human trafficking and is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.

• Whistleblowing policy – the organisation encourages its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation.
• Employee code of conduct – The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• Supplier code of conduct – The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically within the law in their use of labour.
• Agency workers policy – The organisation uses only reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Training

The organisation has provided awareness training for HR professionals, managers and supervisors in relation to:

• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
• what external help is available, for example through the Modern Slavery Helpline and Gangmasters and Labour Abuse Authority

Awareness-raising programme

As well as providing the awareness training above, the organisation has also implemented an awareness-raising programme during 2018/19 financial year by putting up posters on noticeboards and giving access to leaflets for all employees.

• the basic principles of the Modern Slavery Act 2015;
• how employers can identify and prevent slavery and human trafficking;
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
• what external help is available, for example through the Modern Slavery Helpline.

Director approval

This statement was approved on 31st December 2018 by the organisation’s Chief Executive Officer, who reviews and updates it annually.