HUMAN RIGHTS AND MODERN SLAVERY STATEMENT 2023

Feed Factors Limited (a wholly owned subsidiary of The Andersons, Inc.) is a leading supplier of animal feed raw materials and human food, providing a total solution for global sourcing of our customer's commodity requirements.

1. Human Rights Policy statement
1.1 Respect for human rights is a fundamental value of Feed Factors Limited. We strive to respect and promote human rights in our relationships with our employees and suppliers.
1.2 We are intolerant to disrespectful or inappropriate behaviour, unfair treatment or relation of any kind. Discrimination and harassment are not tolerated in the workplace and in any work-related circumstance outside the workplace.
1.3 The health and safety of our employees is of high importance. Our policy is to provide a safe and healthy workplace and comply with applicable health and safety laws and regulations, as well as internal requirements.
1.4 Feed Factors Limited are an equal opportunities employer and positively encourage applications from suitably qualified and eligible candidates regardless of sex, race, disability, age, sexual orientation, gender reassignment, religion or belief, marital status, or pregnancy and maternity. Our aim is to employ people who reflect the diverse nature of society which is why we strive to provide an inclusive environment where individuality is celebrated and we can unleash the potential of our brilliant mix of people.

2. Anti-slavery and human trafficking policy Policy statement
2.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery, all forms of forced labour and any form of human trafficking and we are committed to acting ethically and with integrity in all our business dealings and relationships to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
2.2 We are also committed to ensuring there is transparency in our own business, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners.
2.3 We prohibit the hiring of individuals under 18 years of age for positions in which hazardous work is required.
2.4 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, contractors, external consultants, third-party representatives and business partners.

3. Responsibility for the policy
3.1 The Managing Director holds overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those in our supply chain comply with it.

4. Compliance with the policy
4.1 Employees must ensure that they read, understand and comply with this policy.
4.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
4.3 Employees must notify their manager as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future at the earliest possible stage.
4.4 If an employee is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, it should be raised with their manager.
4.5 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform Human Resources. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

5. Communication and awareness of this policy
5.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
5.2 Our zero-tolerance approach to modern slavery, all forms of forced labour and any form of human trafficking must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

6. Breaches of this policy
6.1 Any employee who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
6.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Company’s Slavery and Human Trafficking statement 2023.

7. Audit and Review
This policy statement will be reviewed annually, in line with the financial year, updated as necessary and re-published accordingly. A copy of the Modern Slavery Act 2015 is accessible electronically, from here: http://www.legislation.gov.uk/... In accordance with Clause 54(7) of the Modern Slavery Act 2015, a copy of this policy is published on the Feed Factors Limited website, and can be viewed here.