Modern Slavery Policy

First published: 21 October 2020  •  Last amended: 16 September 2026

Under the Modern Slavery Act 2015, this statement sets out the steps Bolney Wine Estate is taking to understand and address potential modern slavery risks in its business and to put in place measures to ensure there is no slavery or human trafficking in its business or supply chains. The company is 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.

Business Structure

Bolney Wine Estate is a subsidiary of Freixenet Copestick Ltd, formed in 2019 following the merger of Freixenet UK and Copestick Murray Ltd. Freixenet Copestick is a wholly owned subsidiary of Henkell Freixenet, a family-owned business within Geschwister Oetker Beteiligungen KG (the Oetker Group). The company’s core business is importing and selling still and sparkling wines. Our products are supplied by Group and non-Group companies in the world’s major wine-producing regions.

Due Diligence and Supply Chain

Subsidiaries of the Henkell Freixenet Group are subject to an annual Oetker compliance audit, which includes ethical standards. Managing directors of each subsidiary are ultimately responsible for compliance and are actively involved in the compliance audit.

Prior to supply, third-party suppliers are risk assessed and audited to ensure suitability of supply to the Henkell Freixenet Group. This audit includes staff welfare and the supplier’s ethical standards. We build relationships of trust and integrity with all our suppliers, based on mutually beneficial factors. Our supplier selection and onboarding procedure includes due diligence of a supplier’s reputation, respect for the law, and compliance with health, safety and environmental standards. If the company becomes aware of any evidence of modern slavery within the supply chain, this will be immediately investigated and reported to the authorities.

Training

Key staff with direct responsibility for compliance have undertaken external training to better understand the risks of modern slavery and how to identify them. Staff training is reviewed annually and provided where relevant.

Policies

What Is Modern Slavery?

Modern slavery is a crime and violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Our Zero-Tolerance Approach

We have a zero-tolerance approach to both modern slavery and human trafficking. All employees must be eligible to work in the relevant country, and employment must be freely chosen, with employers not retaining original identification documents. We do not employ anyone under the national minimum working age. All employees are provided with good working conditions, fair treatment and reasonable rates of pay, which are never less than the legal minimum.

Our Internal Policies

The company recognises that the agricultural sector may be one of the risk areas for modern slavery. We operate a number of internal policies to ensure we conduct business in an ethical and transparent manner. These policies include:

• Employee Code of Conduct: Describes the standards of conduct and ethical behaviour the company expects its employees to adhere to.
• Supplier Code of Conduct: Applies to suppliers of the company, requiring strict compliance with the law and with core ILO labour standards.
• Whistleblowing: The company has introduced the Oetker whistleblowing policy. This enables staff, contractors, suppliers, and visitors who become aware of wrongdoing, illegality, or unethical conduct within the company and its supply chains to report their concerns at the earliest opportunity, so they can be investigated and addressed. The confidentiality and anonymity of individuals who report suspected wrongdoing under this policy will be maintained as far as reasonably practicable, and staff will not face reprisals for disclosing concerns, even if they turn out to be mistaken.