Modern Slavery statement

Five Guys Modern Slavery Statement – Financial Year Ending 31 December 2025

We maintain a zero-tolerance approach to modern slavery and human trafficking in all our
operations and supply chains.


This statement sets out the actions taken by the Five Guys JV group to ensure that our supply
chain is free from slavery and human trafficking. It supports our absolute commitment to
prevent slavery and human trafficking in our corporate activities.

Organisational structure and supply chain

1. Five Guys JV is a burger and fries restaurant operation with over 170 stores based in
the UK with continued expansion plans. Our head office is based in West London. Five
Guys JV owns all its stores in the UK and does not franchise any stores. It has 4,650
employees in the UK.

2. We operate restaurants in the UK, Spain, France and Germany through wholly owned
local affiliates. Our ultimate parent company is Five Guys European Holdings Limited
(company number 11249161).

3. Five Guys JV has a pool of approximately 400 food and non-food approved suppliers
(including distributors) through whom all purchases are made.at they comply with them.

We have long standing relationships with our suppliers. We prioritise and, in most cases,
require BRC/GFSI certification for all food-handling suppliers. We do not audit these suppliers
individually since the BRC/GFSI accreditation is the highest food safety standard in the
industry. This also means that they are audited regularly by external auditors in order to
maintain this approval. Within this audit there will be a review of the working environment to
ensure that it is safe, ultimately leading to the welfare of the staff.
In addition, we ask all of our suppliers to sign up to the Five Guys Supplier Code of Conduct
(the “Code of Conduct”).

In our restaurants:
We lease and manage all of our venues ourselves and directly employ all of our restaurant
staff therefore we have full oversight and control over how our own operations are managed.

Standards

We operate within the following policies and principles that describe our approach to the
identification of modern slavery risks and the steps taken to prevent slavery and human
trafficking in our operations:

Employees

1. We promote the respect for workers’ rights and compliance with labour standards by
adopting sustainable, responsible and inclusive workplace practices. We are
committed to not using any form of forced or compulsory or child labour, discrimination
in respect of employment and occupation. We promote a safe and healthy working
environment. We are strongly committed to paying the National Minimum Wage and
use a clock-in clock-out technology to accurately track worked hours.

2. Our anti-bullying and harassment, grievance, diversity equality and inclusion, and our
sexual harassment policies make clear to employees the actions and behaviour
expected of them when representing Five Guys. We strive to maintain the highest
standards of employee conduct and ethical behaviour when operating and managing
our supply chain. We also operate a whistleblowing policy which enables the reporting
of any wrongdoing in the public interest to the attention of managers. Suppliers and
workers in our supply chain can report concerns confidentially through our
whistleblowing channel.

Suppliers
For those of our suppliers that have not signed our Code of Conduct we ensure that they are
committed to complying with equivalent, not less favourable, ethical standards.
As a result we require our suppliers to meet respect and promote human rights and labour
standards (including employee health and safety), and in particular:

  • to respect and support human rights as set out in the United Nations Supplier Code of
    Conduct;
  • to adhere to the minimum age limited defined by laws;
  • to comply with relevant International Labour Organisation (ILO) standards;
  • to support and promote equal opportunities in the workplace;
  • to work to eliminate any form of illegal discrimination in their workplace;
  • to uphold international standards and national labour law work to continually improve
    their workplace and employment standards;
  • not to use child labour;
  • to treat all employees with dignity and respect;
  • to have a proactive employee health and safety program;
  • to comply with all applicable wage and hour laws and regulations;
  • to not discriminate in hiring and employment practices on the basis of race, religion,
    age, nationality, social or ethnic origin, gender, sexual orientation, political opinion or
    disability; and
  • to adopt a zero-tolerance position in relation to modern slavery.

Due Diligence

In selecting our suppliers, we will always evaluate any modern slavery and human trafficking
risks based on a variety of factors which may include their geographical location, size,
reputation and professional accreditations.


As part of our onboarding process, we require all of our “Category A” and “Category B” (core
menu items, critical to brand) suppliers to sign up to the Code of Conduct. We actively seek
their signature and keep their written confirmation of their adherence to it. This is tracked on
Trustwell, a global platform which we use to manage our food safety and suppliers.


In addition, having carried out an gap analysis, we are also implementing an internal modern
slavery toolkit to enable the procurement team to carry out appropriate checks on the those
suppliers which are more likely to hire unqualified staff or staff who do not speak English (this
includes site visits and annual business review questionnaires covering recruitment process
and right to work checks). Our toolkit specifically targets roles or sectors traditionally at greater
risk (e.g., cleaning, logistics, temporary labour) even though such roles are limited in our
business.

Awareness

Given that our operations are fully owned, we employ all staff directly, all suppliers are
Europe-based and of good repute/third-party certified, we assess our overall modern slavery
risk as low. However, we continue to monitor emerging risks.


The Five Guys procurement team are aware of the implications and issues of modern slavery
and human trafficking. This is achieved with new joiner briefings and regular conversations
within the team.


In the next year we will increase training coverage and expand supplier risk-screening through
our internal toolkit.

Board Approval

This statement has been approved by our board of directors who will review and update it
annually.


This statement has been signed by John Eckbert, CEO, on 9th February 2026