Modern Slavery Act Statement

Modern Slavery Statement

Introduction

Modern slavery is a crime and a violation of fundamental human rights. Allowing it to take place within an organisation, either consciously or through complacency, results in extensive and unnecessary suffering - often in a way that disproportionately affects groups of the most disadvantaged people. 

We are committed to acting ethically to implement and enforce effective systems and controls to ensure modern slavery is not taking place within our operations or supply chains.

Our Organisational Structure and Business

We design, make and sell fantasy tabletop miniatures, games and associated hobby products (including books, paints, and other modelling accessories). We also licence our intellectual property (IP) to carefully selected partners to allow them to use our IP in connection with board games, merchandise and apparel, and media and entertainment, that they design, create, and sell.

We are a vertically integrated business, retaining control over every aspect of design, manufacture, and distribution of our miniatures and games. We source a limited number of finished goods, such as modelling tools and spray paints, from suppliers around the globe that we sell under the Warhammer brand.

The Games Workshop head office is located in Nottingham, UK, and includes the main design and manufacturing facilities. Distribution centres to support our global sales network are located in Castle Donington, Derby; Memphis, Tennessee; and Sydney, Australia. 

Our products are sold through a chain of over 560 retail stores in the United Kingdom, the United States, Canada, Australia, New Zealand, Japan, China, Hong Kong, Malaysia, Singapore, France, Germany, Spain, Italy, the Netherlands, Eire, Belgium, Austria, Poland, Norway, Sweden, Denmark, Finland and Switzerland. Products are also sold by our trade partners, which consist of more than 8,000 other hobby, game and toy shops around the world. These outlets are complemented by our global webstore.

During the 2024/25 financial year revenue increased by 16% to £617.5 million.. During this period we also employed 3015 full time equivalent members of staff, with an approximate male to female ratio of 3:1. 

Supply Chain

Our business relies on a network of suppliers for goods and services to support the operations of our business. Whilst a significant portion of these tier one suppliers are based close to our UK head office and manufacturing operations, the scale and diversity of our operations means that we sometimes have to go further afield to find the right supplier. During this financial year 60% of our tier one suppliers were UK based, with another 10% based in Europe, 10% based in North America, and 20% based in the Middle East and Asia.

These tier one suppliers also have their own supply chains and like most businesses our visibility and ability to control or influence the policies, controls, and management processes becomes more challenging the further down the supply chain we go. We have conducted a limited amount of supply chain mapping of these ‘beyond tier one’ suppliers, particularly for the suppliers of material and equipment directly linked to the design and manufacture of our products. 

Risk Management

Modern slavery risks are identified, assessed and managed as part of our company-wide risk management process, which cover both our own operations, and the activities that occur in our supply chain. Risks are identified through a range of processes (such as, work load planning, governance reviews, and scenario planning) at all levels of the business and are recorded on our Modern Slavery Risk Register. Each identified risk is assessed based on the likelihood of occurrence and the potential impact of that risk.The majority of risks are assessed through desk studies but with inputs from third party service providers (for example, Sedex), IGOs, and NGOs (for example, the World Bank and the World Resources Institute). The two key factors used to help inform the assessment of the risk are:

• Sector risk: The inherent risks associated with the particular industrial sector where the identified risk might manifest (for example: materials supply, logistics and distribution, recruitment etc.).

• Region risk: The inherent risk associated with the geographical region where activity associated with the risk takes place.

The level of risk determines the level of due diligence that we undertake to help ensure our standards and expectations are being met with regards to the control and management of any risks of slavery occurring in our operations or supply chain.

The management of modern slavery risks forms an important part of our Social Responsibility and Sustainability (SRS) strategy.  Responsibility for management of modern slavery risks - such as maintenance of our associated policies, training, due diligence processes, monitoring changes in legislation or industry standards, and risk assessment activities - lies with our Head of Social Responsibility and Sustainability, whilst ultimate accountability for modern slavery risks sits with our Board. The group wide operational risk register is reviewed at least twice a year via our Audit and Risk Board Committee.

Whilst we consider the overall risk of modern slavery to be low, we recognise the following areas of our business as being at elevated risk and so additional controls are implemented in order to manage this risk.

Policies

We have a range of policies that are in place to help employees and suppliers understand our expectations and their responsibilities for the fair and ethical treatment of staff, workers, and other people either directly or indirectly involved in the operations of our business. These policies cover areas such as:

• Anti-slavery

• Anti-bribery & corruption

• Equal opportunities

• Health and safety

• Treatment at work

All employees of Games Workshop are required to comply with these policies at all times. Any breach of these policies by a member of Staff may result in disciplinary action being taken, up to and including dismissal from Games Workshop.

Many of these policies and the requirements they set out also form part of our Corporate Social Responsibility (CSR) requirements. These CSR requirements are detailed within our Supplier Manual, Code of Conduct, purchase agreements, and within our standard terms and conditions for the purchase of goods and services and apply to the activities of the supplier and the activities of their own supply chain. The key principles of our CSR requirements are:

• that we undertake all business ethically and with integrity in accordance with all applicable laws and operate in full compliance with our obligations under all applicable anti-slavery legislation, including the Modern Slavery Act 2015

• that we expect those that we we work with to uphold International Labour Organisation (ILO) and other reasonable standards for labour practices, health and safety at work, and other responsible business practices

• that we will not undertake business with any suppliers that do not agree to act in a manner consistent with our commitment against slavery or other responsible business practices laid out in our CSR requirements

• that we review our anti-slavery risk assessments and associated policies at least every 12 months and update our responses to any changes accordingly

Our CSR requirements are communicated to all suppliers of (i) raw materials and components used for the manufacture of our products, and (ii) supplementary products for re-sale. These suppliers must agree to uphold the principles of our CSR requirements in order to be a  supplier of Games Workshop.

Our licensing partners are also required to meet the compliance standards set out within the CSR requirements. This may be achieved by requiring these partners to comply with our standard CSR requirements in the manner detailed here, or by reliance on the ethical codes and standards of those partners where equivalence can be demonstrated.

Any breach of our CSR requirements by a supplier or partner organisation shall result in appropriate action being taken against the supplier or partner organisation, up to and including immediate termination of any business relationship and reporting of the supplier or partner organisation to the relevant authorities.

We do not require low-risk suppliers (e.g. stationary and office furniture) to sign up to our CSR requirements given the low-risk nature of supply.

Due Diligence Processes

As part of our systems and controls to ensure modern slavery is not taking place within our operations or our supply chains, we undertake the following:

• Appropriate vetting and due diligence in respect of suppliers and licensees using desk based risks assessments.

• Whenever possible, we maintain long standing relationships with suppliers, such relationships being based on good supplier performance and trusted compliance with Games Workshop’s CSR requirements and the standards they contain.

• Enhanced auditing and inspections for higher risk areas of the supply chain, such as all suppliers of products and product components. These suppliers are required to undergo independent third party ethical sourcing risk assessments and audits via our audit partner ICTI’s Ethical Supply Chain (ESC) programme. This programme provides a much more bespoke evaluation through direct interviewing and questioning of the supplier. Where concerns are identified, ICTI conducts in-person, unannounced, audits of all supplier facilities, covering the treatment of labour, responsible business practices, health and safety, and environmental management.  Suppliers subject to these extra checks must pass the audits and receive ICTI ESC certification in order to supply us with goods or services. They must also maintain certification through surveillance and renewal audits to remain a supplier.

• Conducting risk assessments every year of both our operations and our supply chain to identify any changes or new areas that may be regarded as being at high risk of exposure to slavery and, where necessary, putting in place additional safeguards such as training or auditing.

• An anonymous whistleblowing process that is operated by a third party. This service is available to anyone wishing to report breaches in our policies or any other instance where they do not believe we have operated in a responsible or ethical manner. All reports are investigated thoroughly.

Reports

Over the last financial year, we have received no reports through our whistle blowing service regarding potential slavery or other human rights abuses within our operations or the supply chain.

Communication and Training

communicate our policies regarding slavery and the treatment of people associated with our operations and supply chain  to all employees, suppliers and licensing partners in the manner described in this statement. Employees that work in high risk areas are required to undertake annual training and pass an associated test to help them understand, identify, and manage any modern slavery risks that they may come across during their duties. This training is also made available to any members of staff that undertake project work in high risk regions or where their manager believes it to be necessary.

Commitment to Improve

We will continue to review and update our policies and procedures as required to ensure that appropriate safeguards are maintained against modern slavery within our operations and our supply chains.

This statement is made on behalf of all companies within the Games Workshop group, including but not limited to, Games Workshop Group PLC, and Games Workshop Limited.

This statement is approved by the Board of Directors of the Games Workshop Group PLC on 19 November 2025, is made pursuant to section 54(1) of the Modern Slavery Act 2015, and constitutes our slavery and human trafficking statement for the financial year ending 1 June 2025.

Kevin Rountree

Chief Executive Officer

Games Workshop Group

19 November 2025