Modern Slavery Statement - Financial Year Ending June 30th 2022


This statement is for Bestway Wholesale Limited, Bestway Northern Limited, Bestway Retail Limited
and Costcutter Supermarkets Group Limited pursuant to section 54(6) of the Modern Slavery Act 2015
(the “Act”). Whilst not meeting the total turnover requirements of Section 54(2) of the Act, MAP
Trading Limited is included in this statement on a voluntary basis. Bestway Wholesale Limited,
Bestway Northern Limited, Bestway Retail Limited, Costcutter Supermarkets Group Limited, and MAP
Trading Limited (together the ”Bestway Wholesale Entities”) represent the following statement for
the financial year ending on 30th June 2022.


Our commitment


The Bestway Wholesale Entities are part of the Bestway Group of companies with the ultimate parent
company being Bestway Group Limited. The Bestway Wholesale Entities fully endorse the aims of the
Act and take a zero-tolerance approach to slavery and human trafficking in their supply chains and
across their businesses. The Bestway Wholesale Entities are committed to preventing slavery and
human trafficking within its own business and in its transactions with other businesses.


Our structure


Bestway Wholesale is the largest independent food wholesaler in the UK, with over 60 Bestway and
Batleys depots across England, Scotland and Wales. Over 130,000 customers in the independent retail
and foodservice industries regularly shop with Bestway Wholesale either within the depots, via the
dedicated customer contact centre, or on the company websites and ordering apps.

The Bestway Wholesale Entities’ independent retail proposition expands across the Symbol Group
brand Best-one, the retail club Xtra Local, and with a range for unaffiliated retailers. Bestway Vans
Direct also operates under the Bestway Wholesale Entities as a delivered van sales service which visits
20,000 customers every two weeks to stock up their snacks and sweets spaces in store, helping them
to sell more, make more and save more.

The Bestway Wholesale Entities’ catering proposition provides for restaurants, cafes, pubs and
takeaway outlets through our range in depots, for contract School’s and University businesses through
BB Foodservice delivered catering proposition and for licensed establishments through Drinks Express
or with our licensed range in depot.

The Bestway Wholesale Entities’ pet product proposition, Bestpets, is the UK’s number 1 per product business which supplies the specialist pet trade and pet retailers nationwide and operates a Pet Retail Club, ‘Bestpets Local’.

Bestway Retail is part a business that is part of the wider Bestway Wholesale operation. Bestway Retail
operates the UK’s largest franchised off-licence and convenience chain. With over 1,150 colleagues
and over 125 stores nationwide, Bestway Retail trades under the Bargain Booze, Select Convenience,
Central Convenience and Wine Rack brands.

Costcutter Supermarket Group, which was acquired by Bestway in February 2021, has over 500
colleagues and 25 stores nationwide and over the last year full integration into our existing Wholesale
and Retail businesses has progressed.

Bestway has over 5,700 employees across these businesses. Offering the best choice and convenience
for customers, we are on a mission to be the best way for a customer to grow their food, drinks or pet


Our suppliers


The Bestway Wholesale Entities purchase products from around the world as well as producing their
own label products. They are committed to acting ethically and expect all of their suppliers to make
the same commitment. The companies will address any failures by our suppliers to meet our standards
on a case-by-case basis and ultimately may lead to the Bestway Wholesale Entities ceasing to trade
with any such supplier. Despite having continuing issues with supply chains as a result of the pandemic,
affecting supply into our suppliers, we remain committed to the particulars in this statement.


Cost of living crisis


We are even more mindful of the need for due diligence in regard to Modern Slavery and the
identification of vulnerable people as a result of the emerging cost of living crisis which will increase
pressure on retailers, customers, suppliers and colleagues.


Within our business


  1. The Bestway Wholesale Entities have a number of People policies and processes that
    demonstrate compliance with UK Employment Law including: Employee Code of Conduct,
    Recruitment Policy, Equality & Diversity Policy, Anti-Bribery Policy and Corporate Social
    Responsibility. All policies are available within our Bestway Wholesale Intranet or are
    published to teams in various formats both online and in hard copy for all colleagues in our
    core Head Office teams, our cash and carry depot teams or our store colleagues in our
    company operated estate. This year we have reviewed all our policies and brought together
    our People Policies of various businesses within the Bestway Wholesale Entities into one
    standard policy set. We have continued to actively communicate that policies are available to
    all colleagues via managers or in our Public Folders, shared drives or Colleague handbook.
  2. We have taken the opportunity to review again the members of our Modern Slavery Steering
    Group that work together across all business units in the Bestway Wholesale Entitiesto ensure
    compliance with the Act and identify colleagues who are likely to have the best impact in this
  3. Our existing Anti-Slavery and Human Trafficking Policy continues to be fit for purpose in our
    current business context.




The Bestway Wholesale Entities positively encourage employees to report any unlawful activity and/or
any activity which may be in breach of policies and procedures through the Whistleblowing Policy.
This includes any circumstances which may give rise to an enhanced risk of slavery or human


Actions achieved


Since publication of the Modern Slavery Statement for the financial year ending 30 June 2021, the
Bestway Wholesale Entities have undertaken the following:


  1. We have further reviewed members for the Modern Slavery Steering Group to ensure we
    have the right number of people involved with Modern Slavery Champions across the
    organisation. They have worked together to deliver our Modern Slavery Commitment
    throughout our wider business and supply chain.
  2. We have continued to use and embed our Modern Slavery Toolkit, so all practice, policy
    and learning is available to managers and colleagues to utilise in their teams.
  3. We have completed a full review of suppliers in retail to ensure they are aware that they
    must comply with Modern Slavery legislation in their supply chains. We have created a
    database with the outputs of these checks, which includes copies of supplier modern
    slavery statements, as appropriate. This review is now an annually updated process.
  4. The full briefing of all depots on Modern Slavery and all supporting materials continues to
    be available this includes ensuring Modern Slavery posters and other supporting collateral
    is available in all depots.
  5. All colleagues in our Head Office complete a standard induction which includes the
    modern slavery training module which is signed off.


Next steps


The Board of Directors of the Bestway Wholesale Entities have ultimate responsibility for the
implementation of policies and procedures, including those related to ethical trading and modern
slavery. We propose the following as next steps;


  1. Ongoing analysis of our supply chain highlighting key risk areas, outputs of which will be
    discussed on a regular basis with the Modern Slavery Steering Group with a view to
    identifying ways to eradicate the identified risk with suppliers.
  2. Continue with the Modern Slavery Steering Group with the identified Modern Slavery
    Champions in the business, including updating the Board of Directors on progress made
    against our commitments throughout the year.
  3. Further update the modern slavery toolkit by creating an online learning module with the
    current content and upload it onto our new Learning Management system so it will be
    available as e-learning for colleagues. This will be completed by all colleagues annually
    going forward.
  4. Actively deliver new training with our store colleagues including regional teams and
    Business Development Managers on how to identify vulnerable people who may be the
    subjected to modern slavery. This will include guidance and support on how to raise this
    within the business so that appropriate action can be taken.
  5. Pilot our training with a small group of our independent retailers sharing a simple toolkit
    that highlights and supports them in identifying potential modern slavery.
  6. Continue with the audit process for our retail suppliers ensuring that all suppliers adhere
    to our Modern Slavery policy, amongst others, through this process.
  7. Follow the same supplier review process as we have with retail suppliers with our
    wholesale supply chain with the outputs kept in our database.
  8. Ensure that the standard posters and educational materials are available at all business




This statement has been considered and approved by the Board of Directors of Bestway Wholesale
Limited, Bestway Northern Limited, Bestway Retail Limited, Costcutter Supermarkets Group Limited
and MAP Trading Limited on behalf of the Bestway Wholesale Entities, who will review and update it


Dawood Pervez


For and on behalf of Bestway Wholesale Limited, Bestway Northern Limited, Bestway Retail Limited,
Costcutter Supermarkets Group and MAP Trading Limited