TilrayBrands UK Ltd
Tilray Brands UK Ltd
Modern Slavery and Human Trafficking Statement 2026
Chief Financial Officer’s Introduction
Modern slavery, in whatever form it takes, remains a fundamental challenge for businesses and society. At Tilray Brands UK Ltd, we are clear that exploitation, forced labour and human trafficking have no place in our business or in the supply chains that support it.
The ’25-’26 financial year marked a period of significant change for our UK operations, following the acquisition of the BrewDog business in March 2026. As we have begun to integrate these operations into Tilray Brands UK Ltd, we have taken the opportunity not only to maintain existing safeguards but to strengthen our approach to identifying and addressing modern slavery risks across our organisation.
We recognise that the risks associated with modern slavery are not static. They evolve with global supply chains, economic pressures and changes in labour markets. While we assess the risk within our direct UK operations to be low, we remain conscious that risks may arise further upstream, particularly in global supply chains where visibility and control can be more limited.
We have focused on embedding consistent standards across our UK business, strengthening supplier engagement, and aligning our approach with wider Tilray group practices. We have continued to expand our supplier attestation programme, enhance procurement training, and improve our understanding of risk through more structured assessments.
Looking ahead, our priority is to deepen our engagement with suppliers, further strengthen our governance and monitoring, and continue building a culture where risks are recognised early and addressed responsibly.
Carl Merton
Chief Financial Officer
Tilray Brands UK Ltd
Our Business
Tilray Brands UK Ltd is part of the global Tilray Brands group, a consumer packaged goods company operating across beverages, alcohol, pharmaceutical, and wellness sectors.
In 2026, Tilray Brands UK Ltd acquired the BrewDog business and assets from companies in administration and now owns and operates the BrewDog brand and business in the United Kingdom and elsewhere. This includes brewing, hospitality, retail and associated intellectual property and operations.
In the UK, our activities include brewing and packaging, operating bars, hotels and taprooms, managing retail and e-commerce channels, and working with franchise and licensed partners.
Our business is supported by a diverse and extended supply chain, spanning raw materials, packaging, logistics and a wide range of goods and services required to operate in both manufacturing and hospitality environments.
Our Structure and UK Entity
This statement is made on behalf of Tilray Brands UK Ltd (company number 13578781), which is the entity that owns and operates the BrewDog business in the United Kingdom.
As our UK operating model continues to evolve following the 2026 acquisition, we will review the scope of this statement annually to ensure that all relevant UK entities remain appropriately covered.
Our People
Across our UK operations, we employ a broad workforce spanning brewing, hospitality and corporate functions.
We are committed to ensuring that all individuals working within our business are treated fairly, with respect and in accordance with applicable laws and standards. All employees are engaged through formal contracts, supported by appropriate right-to-work checks, and operate within a framework of policies designed to prevent exploitation.
We recognise the importance of creating an environment where people feel able to raise concerns. Confidential reporting mechanisms are available to employees, and we continue to reinforce awareness of these channels.
Where we rely on third-party labour providers, we require them to meet equivalent standards and to comply with our contractual and ethical expectations.
Our Supply Chain
Our supply chain is global and supports both brewing and hospitality operations. It includes suppliers of raw materials such as hops and barley, packaging materials, merchandise, equipment, logistics services and professional support services.
Like many businesses operating at scale, we recognise that a significant proportion of modern slavery risk can sit beyond the first tier of suppliers. While many of our direct suppliers operate in regions with strong regulatory frameworks, certain inputs, particularly packaging and manufactured goods, may originate from jurisdictions where the inherent risk is higher.
Understanding and managing these risks requires continuous engagement, improved transparency and a willingness to challenge and support suppliers in equal measure.
Our Policies and Governance
Our approach to modern slavery is underpinned by a framework of policies that set clear expectations for both employees and suppliers.
These include our Workplace Code, supplier standards, anti-bribery policies and whistleblowing procedures. Together, these establish a consistent baseline: forced labour, child labour and human trafficking are strictly prohibited and will not be tolerated.
Responsibility for oversight sits across our legal, procurement, ESG and compliance functions, working collaboratively to ensure that modern slavery risks are identified and addressed. These activities are informed by group-level policies and practices within Tilray Brands, helping maintain consistency while reflecting local requirements.
Due Diligence and Supplier Engagement
We have adopted BrewDog’s supplier due diligence processes and will continue to strengthen these as we integrate within the wider Tilray Brands group.
All new suppliers are subject to onboarding procedures that include contractual commitments on labour standards and ethical conduct. We have embedded modern slavery considerations into supplier qualification processes and continued to expand our use of supplier attestations, requiring suppliers to confirm their compliance with relevant laws and their approach to managing risks within their own supply chains.
Our approach is risk-based. We prioritise engagement with suppliers operating in higher-risk categories or geographies and take additional steps where required, including further verification or enhanced due diligence.
We recognise that this is an ongoing process. Building transparency and trust across the supply chain takes time, and we continue to develop tools and processes that support more effective monitoring and engagement.
Understanding and Managing Risk
We assess the risk of modern slavery within our direct UK operations as low, reflecting the regulated environments in which we operate and the controls we have in place.
However, we remain alert to risks that may arise within our supply chain, particularly further upstream. These may relate to labour-intensive production processes, reliance on low-skilled or migrant labour, or sourcing from regions with weaker labour protections.
Our aim is not only to identify these risks but to understand them in context, allowing us to respond in a proportionate and effective way. This includes ongoing work to improve visibility across our supply chain and to ensure that risk considerations are embedded within procurement and operational decision-making.
Training and Awareness
We recognise that policies and processes alone are not sufficient to address modern slavery risks. Awareness across the organisation is critical.
Employees have access to training that covers ethical conduct, compliance and modern slavery risks, with targeted training provided to procurement and other relevant teams. These programmes are designed not only to inform but to enable practical decision-making and escalation where concerns arise.
We will continue to build on this foundation, ensuring that training remains relevant and aligned with the evolving nature of the risks we face.
Measuring Effectiveness
We assess the effectiveness of our approach through a combination of qualitative and quantitative measures.
These include supplier engagement metrics such as attestation completion rates, training participation levels, and the coverage of contractual protections across our supplier base. We also monitor reports raised through internal channels and track how concerns are investigated and resolved.
During the reporting period, we did not identify any instances of modern slavery within our operations or supply chains. However, we recognise that the absence of reported cases does not eliminate risk, and we remain committed to continuous improvement.
Working with the Tilray Group
This statement has been prepared in consultation with relevant teams across the wider Tilray Brands group, including legal, procurement, ESG and compliance functions.
We have drawn on group-level policies, risk assessments and supply chain practices to inform our approach, ensuring alignment with broader standards while addressing the specific characteristics of our UK operations.
Looking Ahead
As we continue to embed the BrewDog business within Tilray Brands UK Ltd, our focus remains on strengthening our approach to managing modern slavery risks.
Over the coming year, we will:
- deepen engagement with suppliers, particularly in higher-risk areas
- continue expanding supplier attestation coverage
- further align with group-level policies and frameworks
- enhance our data and reporting capabilities
- reinforce training and awareness across the business
We will also explore the development of a single consolidated group statement in future years, while ensuring that UK statutory requirements continue to be clearly met.
Approval
This statement has been approved by the Board of Directors of Tilray Brands UK Ltd and is signed on its behalf by:
Carl Merton
Chief Financial Officer
Tilray Brands UK Ltd
Date: [●] 2026
