Standards & Governance

Introduction

Thomas Cradley Limited is the ultimate holding company of the Suttons Transport Group which includes Suttons Tankers Limited and Suttons International Limited (hereinafter referred to as “Suttons” or “Suttons Group”).

Security

Suttons has a rigorous approach to all aspects of security, whether it involves security of data, people, assets or client property and products. We carry out regular reviews and discussions with the appropriate security authorities to ensure the Suttons Group is maximizing its capabilities in these areas.

Bribery and Price Fixing Statement

Suttons Group is committed to conducting all of its business in an honest and ethical manner.

It is unacceptable for any Director or employee of any Suttons Group company to make or accept bribes or to collude with competitors to fix prices or rig tenders.

The Suttons Board and senior management will take all reasonable measures to prevent Bribery and Price Fixing including risk assessment, procedures, policies, and training to ensure that all relevant employees are aware of their legal and moral responsibilities.

The Suttons Board will create a culture that encourages those who have suspicions that Bribery or Price fixing is occurring to come forward and report their concerns, will ensure that they are protected and that the allegations are investigated and, where the allegations are proven, appropriate action is taken against the individuals engaged in such practices.

Anti Facilitation of Tax Evasion Statement

The Criminal Finances Act 2017 places a legal obligation on all UK companies to have and uphold policies which prevent the facilitation of tax evasion. The act applies to all of a company’s dealings, wherever they occur in the world.

Suttons Group will conduct all of our business dealings, wherever they occur in the world, in an honest and ethical manner. We will take a zero-tolerance approach to facilitation of tax evasion, whether under UK law or under the law of any foreign country. We will assess the risk of being involved in tax evasion in our own right, or being asked to facilitate the evasion of tax by customers, suppliers or others with whom we have business dealings. We will ensure that our staff are aware of their obligations through clear communication of our policies and, where appropriate, training.  We will uphold all laws relevant to countering tax evasion, including the Criminal Finances Act 2017.

Suttons Group: Modern Slavery Act 2015:  slavery and human trafficking statement

Introduction from the Thomas Cradley Limited  chief executive officer.

Suttons Group is committed to driving out acts of modern day and human trafficking slavery from within its own business and from within its supply chains. The company acknowledges responsibility to the Modern Slavery Act 2015 and will ensure transparency within the organization and with suppliers of goods and services to the organization.

Organization’s structure

We are a global supplier of transport and related services in the logistics sector. The Group has over 1,300 employees worldwide and operates in 9 countries. The Group has a global annual turnover of £ 332 million.

Our supply chains

Our supply chains include various suppliers of Goods and Service both in the UK and overseas.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern day 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.

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk we have in place systems to:

·       Identify and assess potential risk areas in our supply chains;

·       Mitigate the risk of slavery and human trafficking occurring in our supply chains;

·       Monitor potential risk areas in our supply chains; and

·       Protect whistleblowers.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance program and we have a dedicated compliance team, which consists of representatives from the following departments:

·       Legal;

·       Human resources; and

·       Procurement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 31^st March 2025.

John Sutton Chief Executive Officer

Thomas Cradley Limited

Date: 2 April 2024