Corporate Responsibility

Modern Slavery Act Transparency Statement

Our commitment to ethical business, responsible sourcing and the prevention of modern slavery and human trafficking within our business and supply chains.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps taken by Berens Group Limited and its subsidiary companies (the Group), trading principally as Berry's Jewellers, to prevent modern slavery and human trafficking within our business and supply chains during the financial year ended 30 June 2026.

01

Our Business

Who we are and how our supply chain is structured.

Berry's Jewellers is an independent, family owned luxury jewellery and watch retailer, founded in 1897. We operate retail stores across the United Kingdom together with our online business.

Our business sources watches, jewellery and associated products from established manufacturers and suppliers in the United Kingdom and internationally. Our supply chain includes luxury watch manufacturers, jewellery manufacturers, diamond and gemstone suppliers, workshops and suppliers of packaging, services and other ancillary products.

We do not tolerate slavery, servitude, forced or compulsory labour, human trafficking or any other form of modern slavery within our own business or our supply chains.
02

Our Approach & Policies

The standards we expect within our business relationships.

We are committed to conducting our business ethically, responsibly and with integrity.

Our policies and procedures are intended to support this commitment and to ensure that those working for us, and those with whom we do business, understand the standards we expect.

We expect suppliers and business partners to comply with all applicable employment, labour and human rights legislation and to share our commitment to preventing modern slavery and human trafficking.

This includes an expectation that workers:

  • are employed voluntarily and are not subject to forced, bonded or compulsory labour;
  • are not required to surrender passports or identity documents as a condition of employment;
  • meet applicable minimum age requirements;
  • receive wages and benefits in accordance with applicable laws;
  • work within applicable legal requirements concerning working hours and conditions; and
  • are treated fairly and with dignity and respect.
03

Supply Chain Due Diligence

How we consider responsible sourcing and supplier standards.

We recognise that modern slavery risks can occur at different stages within global supply chains and that responsible sourcing requires ongoing scrutiny.

As part of our supplier selection and review processes, we consider the ethical and responsible sourcing practices of our suppliers. Where appropriate, suppliers may be asked to provide information concerning their policies, working practices, supply chains and procedures for identifying and addressing modern slavery and human rights risks.

We maintain relationships with established suppliers and manufacturers and seek to work with businesses that demonstrate standards consistent with our own.

Where a material concern is identified, we reserve the right to request further information, seek appropriate corrective action, review the relationship or cease trading with a supplier where satisfactory action is not taken.

04

Risk Assessment

A proportionate approach to identifying and managing risk.

Our approach is proportionate to the nature of our business and the potential risks within our supply chains.

We seek to identify areas where there may be an increased risk of labour exploitation or modern slavery and to focus our due diligence accordingly. We recognise that risks may change over time and that continued engagement with suppliers is an important part of managing those risks.

New suppliers may be subject to additional due diligence before a trading relationship is established, particularly where the nature or location of the supply chain indicates an increased level of risk.

05

Training & Awareness

Maintaining awareness across relevant teams and management.

We are committed to maintaining awareness of modern slavery and human trafficking within our business.

Relevant employees and managers are made aware of our approach to modern slavery and are encouraged to raise any concerns regarding practices within our business or supply chain.

Any concern relating to suspected modern slavery, exploitation or unethical employment practices will be taken seriously and considered appropriately.

06

Monitoring Our Effectiveness

Reviewing our approach and continuing to strengthen our processes.

We continue to review our approach to modern slavery and responsible sourcing.

Our ongoing measures include:

  • reviewing modern slavery and human rights risks within our supply chains;
  • reviewing relevant supplier policies and due diligence information;
  • considering modern slavery risks when appointing new suppliers;
  • engaging with key suppliers where further information or assurance is required;
  • maintaining awareness among relevant employees; and
  • reviewing and updating our procedures where improvements are identified.

We recognise that addressing modern slavery requires continued diligence and that our approach should develop as our business, supply chains and the wider understanding of modern slavery risks evolve.

Our Commitment

Continuing to Uphold High Ethical Standards

Berry's Jewellers is committed to maintaining high ethical standards throughout its business relationships. We will continue to work with our suppliers, employees and business partners to identify, prevent and address modern slavery and human trafficking risks wherever they may arise.

This statement has been approved by the Board of Directors of Berens Group Limited and will be reviewed and updated annually.

Approved By Simon Walton Managing Director Berens Group Limited 1 July 2026

Modern Slavery Act Transparency Statement, Berens Group Limited and Subsidiary Companies, published 1 July 2026.