Code of Ethics

Bradshaw Taylor is committed to conducting business honestly, responsibly and with integrity. We expect everyone working for or on behalf of the business to act lawfully, ethically and professionally, and to treat others with fairness, dignity and respect.

This includes avoiding bribery, corruption, fraud, conflicts of interest, discrimination, harassment and other irresponsible or dishonest practices. Employees and representatives are expected to maintain accurate records, protect confidential information, make responsible decisions and raise concerns where conduct falls below expected standards.

Bradshaw Taylor will not tolerate retaliation against anyone who raises a genuine concern in good faith. This Code helps protect the business by setting clear expectations, reducing legal and reputational risk, and supporting a culture of integrity and accountability.

The purpose of this Code is to:

• Set clear expectations for ethical conduct across the business
• Reduce legal, regulatory and reputational risk
• Support responsible decision-making and good governance
• Help protect against corruption, misconduct and irresponsible working practices
• Promote a culture of accountability, respect and integrity

VALUE IN ACTION — Responsibility: we take ownership of ethical conduct across the business and hold ourselves accountable when we fall short.

This Code applies to:

• All employees
• Directors and senior leaders
• Temporary workers, agency workers and contractors
• Consultants, intermediaries and other representatives acting on behalf of Bradshaw Taylor

This Code applies in all areas of Bradshaw Taylor's business activities, including relationships with customers, suppliers, brand partners, service providers and other stakeholders.

Bradshaw Taylor expects everyone working for or on behalf of the business to act ethically, professionally and in the best interests of the company and its stakeholders.

We are committed to conducting business in a way that is honest, fair and responsible. This means complying with the law, treating people with dignity and respect, avoiding improper conduct, and making decisions that reflect our values as well as our commercial responsibilities.

Unethical behaviour, including corruption, dishonesty, misconduct or irresponsible working practices, will not be tolerated.

Bradshaw Taylor will seek to apply the following principles across its business activities:

Integrity — we act honestly and take responsibility for our actions and decisions.

Respect — we treat colleagues, partners, customers and stakeholders fairly, professionally and with dignity.

Accountability — we take ownership of our conduct, raise concerns where needed, and follow through on actions and commitments.

Responsibility — we consider the wider impact of our actions on people, communities, business partners and the environment.

Transparency — we communicate openly and keep accurate, truthful records.

Fairness — we aim to make decisions objectively, consistently and without improper bias or influence.

Everyone working for or on behalf of Bradshaw Taylor is expected to:

• Comply with applicable laws, regulations and internal policies
• Act honestly and in good faith
• Avoid bribery, corruption, fraud or dishonest conduct
• Declare and manage conflicts of interest appropriately
• Treat others with dignity, fairness and respect
• Avoid discrimination, harassment, bullying or retaliation
• Protect confidential information and company assets
• Maintain accurate records and truthful communications
• Raise concerns where behaviour or practices fall below expected standards

Bradshaw Taylor expects high standards of integrity in all business dealings.

This includes:

• No bribery, corruption or improper payments
• No misleading, false or dishonest statements
• No falsification of records, invoices, reports or expenses
• No abuse of position for personal or business gain
• No concealment of unethical or unlawful conduct

Any gifts, hospitality, expenses or business courtesies must be handled appropriately and must not influence, or appear to influence, business judgement.

VALUE IN ACTION — Pride: we hold ourselves to a high standard of honesty and record-keeping — because trust, once lost, is hard to rebuild.

Bradshaw Taylor is committed to promoting responsible working practices across the business.

This includes:

• Fair treatment of employees and workers
• Respect for human rights and labour standards
• Safe and healthy working conditions
• Lawful and responsible employment practices
• Appropriate support for speaking up and reporting concerns
• Protection from retaliation for raising genuine concerns

We also expect business partners and suppliers to operate responsibly and ethically.

All actual, potential or perceived conflicts of interest must be disclosed promptly and managed appropriately.

Individuals must not allow personal interests, relationships or outside activities to improperly influence business decisions.

Bradshaw Taylor competes fairly and complies with applicable competition and antitrust law in every market in which it operates.

• No agreements or understandings with competitors on prices, discounts, terms, output, markets or customers
• No bid-rigging, market-sharing or collusive tendering
• No abuse of a dominant market position
• No exchange of competitively sensitive information with competitors, including through trade associations
• Seek legal advice before entering arrangements with competitors, or where competition law risk is unclear

Breaches of competition law can result in severe penalties for Bradshaw Taylor and for individuals, and will be treated as a serious matter under this Code.

Bradshaw Taylor depends on the trust of its employees, customers, suppliers and partners to handle information responsibly. Everyone working for or on behalf of the business is expected to:

• Protect confidential, personal and commercially sensitive information from unauthorised access, use or disclosure
• Follow Bradshaw Taylor's data protection, IT security and acceptable-use requirements
• Use strong access controls and safeguard passwords, devices and company systems
• Report suspected data breaches, phishing attempts or other security incidents promptly
• Use company information and systems only for authorised business purposes

Employees and representatives who handle sensitive information have a personal responsibility to protect it, in addition to the safeguards Bradshaw Taylor puts in place.

Bradshaw Taylor encourages employees and stakeholders to speak up if they become aware of unethical, unlawful or irresponsible conduct.

Concerns may be raised through:

• A line manager
• Another manager
• HR / People team
• A senior leader or director
• Grievance, whistleblowing or speak-up channels
• Anonymous reporting routes, where available

All genuine concerns will be taken seriously and handled fairly and appropriately.

VALUE IN ACTION — Collaboration: we make sure there are multiple safe, trusted ways to speak up — not just one.

Bradshaw Taylor will not tolerate retaliation against anyone who raises a concern in good faith or supports an investigation.

Any intimidation, victimisation, disadvantage or unfair treatment linked to speaking up will be treated as a serious matter.

Any breach of this Code may result in disciplinary action, up to and including dismissal where appropriate. Bradshaw Taylor may also take action in relation to third parties who fail to meet expected ethical standards.

Where necessary, matters may be escalated through legal, regulatory or other appropriate channels.

Ethical conduct is supported by responsible governance. The Senior Leadership Team oversees material ethical, conduct and compliance risks, and significant decisions are expected to follow Bradshaw Taylor's decision-making and governance frameworks, including the Stakeholder Governance Policy where a decision is material to stakeholders. This helps ensure that ethical considerations are built into how decisions are made, not treated as a separate afterthought.

Bradshaw Taylor will review ethical risks, concerns and patterns over time to strengthen controls, improve guidance and support responsible business conduct. This may include reviewing:

• Grievances and whistleblowing themes
• Conflicts of interest
• Misconduct issues
• Supplier or partner concerns
• Governance and compliance actions

Implementation of this Code is evidenced through Bradshaw Taylor's operational records, including the Conflict of Interest Register, the Gifts and Hospitality Log, and training completion records for ethics, anti-bribery and related training. These records support monitoring, demonstrate accountability, and help identify where further guidance or controls may be needed.

VALUE IN ACTION — Growth: we use what we learn — from grievances, audits and reviews — to keep strengthening our ethical culture.

This Code should be read alongside:

• Anti-Bribery and Corruption Policy
• Conflict of Interest Policy
• Gifts and Hospitality Log
• Whistleblowing and Grievance Policy
• Human Rights Policy and Human Rights and Supplier Due Diligence Procedure
• Anti-Harassment, Bullying and Discrimination Policy
• Stakeholder Governance Policy
• Data protection and information security policies

This Code will be reviewed at least annually to ensure it remains effective, practical and aligned with Bradshaw Taylor's values and governance commitments.

Approved by: Sarah Gould, Group HR Manager
Signature:
Date approved: July 2026
Version: 2.0
Next scheduled review: 01 July 2027